- 8 - v. Commissioner, supra at 543-544, we find that petitioners are entitled to $500 in contributions for each of the 3 taxable years. Petitioners purchased supplies, teaching aides, and computer items in connection with their teaching activity. In addition, petitioners had expenditures for the maintenance of their computers. To some extent, the computers were used for personal purposes. At trial, petitioners provided some documentation of their expenditures concerning their employee business expenses. The amounts documented were less than one-half of the amounts claimed for 1992 and 1993. However, some of the documentation for one year provided a basis for allowance of a similar amount in the other year. For example, petitioners provided substantiation of $771.92 for union dues in 1993, and respondent conceded that amount. The claimed deductions relating to computers are subject to the more rigorous requirements of section 274(d) because they are "listed property" as described in section 274(d)(4) and listed in section 280F(d)(4)(A)(iv). See also sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). In that regard, petitioners provided specific proof of computer expenditures during 1992 and 1993 in the amounts of $1,224.40 and $1,668.93. Taking into consideration personal use, we hold that petitioners are entitled to employee computer-related businessPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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