Linda Klyce - Page 18




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          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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