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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
280F(d)(4).
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
expenses.
D. Phone Expenses
Respondent disallowed the claimed telephone expenses on the
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