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Telephone Expense
In 1993, petitioners had only one telephone line. The total
phone bills for that year were $587.97. In preparing their tax
returns, petitioners subtracted the basic monthly charge and
claimed the balance of $505 as deductible. Mrs. Popov claimed
that both she and Mr. Popov made long distance calls for her
business. Mrs. Popov testified that all long distance calls were
business calls, yet she did not elaborate on the business purpose
of these calls.
Section 262(a) provides that no deduction shall be allowed
for personal, living, or family expenses. Section 262(b)
provides that any charges, including taxes, for basic local
telephone service for the first telephone line of the taxpayer’s
residence are treated as personal expenses for the purposes of
section 262(a).
Petitioners submitted all of their telephone bills for 1993.
There were telephone calls that were late at night, for long
periods of time, and to foreign countries. Since petitioners did
not identify the business purposes of any long distance calls,
they are deemed to be personal and not deductible.
Car and Truck Expenses
Mrs. Popov drove to 38 different locations in order to play
the violin for the various orchestras. The contractors used
different studios according to what was available. Mrs. Popov
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