- -18 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 thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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