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are treated as personal expenses for the purposes of section
262(a).
Petitioners argue that the telephone expenses are deductible
as business expenses under section 162(a), and therefore the
deduction of such expenses is otherwise expressly provided.
Petitioners ignore the explicit language of section 262(b).
Petitioners failed to offer any testimony or evidence as to
whether the telephone expenses claimed include long distance
charges for business purposes. Thus, petitioners have failed to
establish that they are entitled to a deduction for telephone
expense. Respondent is sustained on this issue.
C. Other Expenses
Petitioner testified that he incurred checking account fees
during 1991. Petitioners did not argue that they are entitled to
a deduction for these fees in either of their posttrial briefs.
Moreover, petitioners have not established that the amount of
fees paid or that the fees were incurred for business purposes.
Petitioners are not entitled to a deduction for any checking
account fees.
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