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Commissioner, 85 T.C. 731, 743 (1985). Without such a basis, any
allowance would be unguided largesse. Williams v. United States,
245 F.2d 559, 560 (5th Cir. 1957).
Respondent argues that expenditures within the following
categories should be disallowed entirely, or in the alternative,
that the expenditures must be capitalized. Petitioner argues
that the same expenditures are currently deductible. The
disputed categories include: Travel expenses, utilities,
cellular phone service, cable service, advertisements, clock
repair, truck rental, real estate license, taxes, and
miscellaneous.
Travel Expenses
A deduction for travel expenses may be allowed where the
expenses are incurred while "away from home", are reasonable and
necessary, and bear a proximate relation to the profit-seeking
activity. Kinney v. Commissioner, 66 T.C. 122, 126 (1976);
McKinney v. Commissioner, T.C. Memo. 1981-181, affd. 732 F.2d 414
(10th Cir. 1983). Travel expenses must also be substantiated as
required by section 274(d).
Respondent disallowed an $832 deduction for meals, a $1,402
deduction for amounts paid to various oil companies, a $1,369
deduction for auto repairs, deductions of $119.50, $465, and $76
alleged to be for insurance on the Lincoln, and depreciation
deductions on the Lincoln.
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