8 274(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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011