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deductible. Therefore, we sustain respondent's disallowance of
the claimed deduction for home office expenses.
Petitioner and Mr. Velinsky deducted $2,471 in expenses for
the year at issue which were claimed to be for utilities
applicable to the home office and for business use of the home
telephone. We deny any utility expense deductions relating to
the home office for the reasons mentioned above. Petitioner
offered telephone bills and other substantiating documentation to
show the actual business use of the telephone, primarily long
distance calls. Mr. Paquette explained to the auditor, and
petitioner testified, that Mr. Velinsky used the telephone in his
band management business. Under Cohan v. Commissioner, 39 F.2d
540 (2d Cir. 1930), we allow $30 per month for Mr. Velinsky's
business telephone expenses for long distance calls.
Petitioner and Mr. Velinsky also deducted expenses for
interest, legal and professional services, and admissions.
Petitioner has offered no evidence to substantiate these
deductions, and we hold that petitioner has not met her burden of
proof with regard to these claimed deductions.
Section 274(d) states that a taxpayer is not allowed a
deduction under section 162 for any travel or entertainment
expense, unless the taxpayer has substantiation, in the form of
adequate records or other sufficient corroborating evidence,
showing: (1) The amount of the expense; (2) the time and place
of the travel or entertainment; (3) the business purpose of the
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