- 18 -
child. The record does not disclose the number of phone calls,
if any, made in those months in connection with a day care
activity for the care of only one child, nor does the record show
that it was necessary to incur significant long-distance
telephone charges in connection with the care of that child.
These expenses were more likely personal expenses of petitioner
that were paid out of an account in the name of Klyce Day Care
and, as such, are not deductible as trade or business expenses
under section 162(a).10
The next item is supply and equipment expense and food
expense deductions for 1991 and 1992, respectively, in connection
with Sweets 'N' Things. Petitioner contends she is entitled to a
deduction for the food expenses in amounts greater than that
allowed by respondent. On her 1991 amended return, petitioner
claimed $3,568 for supply and equipment expenses. The entire
amount was disallowed by respondent. Petitioner did not present
evidence to satisfy the Court that she is entitled to a supply
9(...continued)
of $41.01 and Pacific Bell in the amount of $84.18, totaling
$125.19.
10
Sec. 262(a) provides generally that no deduction shall be
allowed for personal, living, or family expenses. Sec. 262(b)
provides further that, for purposes of subsec. (a), in the case
of an individual, any charge for basic local telephone service
with respect to the first telephone line provided to any
residence of the taxpayer shall be treated as a personal expense.
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