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274(d). Listed property includes automobiles and cellular
telephones. Sec. 280F(d)(4). Section 274(d) requires
substantiation of these expenses either "by adequate records or
by sufficient evidence corroborating the taxpayer's own
statement".
Petitioner testified that his business mileage was based on
an estimate. He also testified that his 1993 telephone expense
represented amounts paid to a friend from whom he borrowed a
cellular phone. Petitioners presented no records or
corroborating evidence with respect to these expenses, and they
have failed to substantiate any amount in excess of that allowed
by respondent. Respondent is sustained on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011