- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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