Les B. Martin and Millie A. Martin - Page 15

          Tax-Work Expenses                                                           
               Petitioners now claim entitlement to deduct $720 as tax-work           
          (audit) expenses for 1989.  Most of these expenses are for travel           
          to petitioners' attorney's office and related activities for                
          earlier years.  Respondent argues that petitioners did not                  
          substantiate mileage expenses as required by section 274(d).2  We           
          agree with respondent; accordingly, we sustain respondent's                 
          disallowance of the deduction for tax-work (audit) expenses.                
          Schedule C Expenses                                                         
               Petitioners originally claimed a $9,763 Schedule C business            
          loss for 1989, that resulted from their claiming $11,540 in                 
          business expenses and $1,778 in income.  The statutory notice               
          disallowed $9,361 of the expenses claimed as a section 179                  
          deduction.3  On their original 1989 return, petitioners claimed             
          $12,860 in expenses relating to the business of Mr. Martin.  On             
          their amended 1989 return, petitioners claimed $12,860 in expenses          
          relating to the business of Mr. Martin and $8,914 in expenses               

               2    The requirements imposed by sec. 274(d) are in addition           
          to those of sec. 162.  Furthermore, in the case of travel                   
          expenses, sec. 274(d) overrides the Court's ability to                      
          approximate a taxpayer's allowable expenses under the Cohan                 
          doctrine.  Sanford v. Commissioner, 50 T.C. 823, 826-828 (1968),            
          affd. per curiam 412 F.2d 201 (2d Cir. 1969).                               
               3    Sec. 179(a), in general, allows a taxpayer to elect to            
          expense the cost of certain property (known as sec. 179 property)           
          for the taxable year in which the property is placed in service.            
          In general, sec. 179 property is tangible property used in the              
          active conduct of a taxpayer's trade or business that would be              
          subject to depreciation but for the election.                               

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