- 26 - convinced by petitioner's general statements and the evidence submitted at trial that he actually incurred such an expense. To substantiate the purchase of the facsimile machine, petitioner submitted a generic American Express receipt for $640 from Radio Shack. However, that receipt does not specify the item charged, and petitioner simply wrote in "fax machine". Thus, petitioner has failed to establish that he actually purchased a facsimile machine. Accordingly, we sustain respondent's determination with respect to this item. However, with respect to the cost of the facsimile stand, we allow petitioner to deduct $130, since he submitted a bill for this amount which shows a description of the item purchased. Furthermore, we can reasonably infer that petitioner used the facsimile stand in his business. Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). With respect to the telephone, chairs, desk lamp, computer desk, and computer stand, we note that Congress, in enacting section 280A, intended to preclude expenses "otherwise considered nondeductible personal, living, and family expenses * * * [from being] converted into deductible business expenses" merely because they have some connection to a business activity. S. Rept. 94-938 at 147 (1976), 1976-3 C.B. (Vol. 3) 49, 185. Prior to the enactment of section 280A, there was congressional concern that some taxpayers were deducting personal expenditures under the guise of business use of the home. Hamacher v. Commissioner, 94 T.C. 348, 357 (1990) (citing Green v.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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