Gregory A. Maslow and Marina Maslow - Page 11

          personal residence. In this regard, respondent's notice of                  
          deficiency states, in pertinent part:                                       
               Taxpayer is an insurance agent and works for various                   
               insurance companies as a salesman.  Taxpayer stated that               
               he had an office in the home.  The taxpayer was asked to               
               provide substantiation for his expense as well as the                  
               insurance policy on his home and failed to do so.                      
               Taxpayer then stated that his expense is for his car but               
               failed to bring any records to verify this statement.                  
               In general, section 274(d) provides that no deduction shall be         
          allowed as a trade or business expense for any traveling expenses           
          or with respect to any listed property, as defined in section               
          280F(d)(4), unless the taxpayer substantiates by adequate records           
          or by sufficient evidence corroborating the taxpayer's own                  
          statement the business purpose of the expense. A passenger                  
          automobile is a "listed property" within the purview of section             
               Petitioner failed to provide the requisite substantiation that         
          would enable petitioners to deduct the purported insurance expenses         
          on the automobile allegedly used in connection with petitioner's            
          insurance business.  Moreover, respondent did allow a deduction             
          (under the heading "travel expenses", see supra) in the amount of           
          $2,703 as automobile travel expenses incurred in connection with            
          petitioner's insurance business. Accordingly, we sustain                    
          respondent's disallowance of the claimed $1,983 of insurance                
               D.  Phone Expenses                                                     
               Respondent disallowed the claimed telephone expenses on the            

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