- 16 -
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
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011