Pennel Phlander Irwin - Page 16

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                  We also reject petitioner's claims for deductions related to                            
            the expense of insuring his vehicles.  As previously discussed,                               
            petitioner has failed to establish any business use of the                                    
            vehicles in question.  Therefore, we sustain respondent on this                               
            issue.                                                                                        
                        (E)  Office Expenses/Supplies                                                     
                  Petitioner claims deductions for "supplies" related to his                              
            literary activities.  Most of these expenses, such as furniture                               
            for his residence, a washing machine, and a microwave oven, are                               
            inherently personal.  Section 262 precludes such deductions.  The                             
            record, however, indicates that petitioner incurred deductible                                
            expenses for stationery and envelopes.  We allow petitioner a                                 
            deduction with regard to these expenses in amounts equal to $5.55                             
            in 1990 and $35.43 in 1991.                                                                   
                        (F)  Travel, Meals, and Entertainment                                             
                  Taxpayers may deduct travel expenses incurred while away                                
            from home in pursuit of a trade or business.  Sec. 162(a)(2).                                 
            Traveling expenses, however, are governed by the strict                                       
            substantiation requirements of section 274(d).  Under section                                 
            274(d), petitioner must substantiate the amount of the expense,                               
            the time and place of the travel, and the business purpose of the                             
            expense.  If petitioner fails to meet the provisions of section                               
            274(d), we cannot employ the principles of Cohan v. Commissioner,                             
            39 F.2d 540 (2d Cir. 1930), to estimate petitioner's travel                                   






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