- 3 - carried on a Schedule C business called "Adaptable Business Concepts" during 1992. Petitioners claimed a Schedule C deduction for utility expenses in the total amount of $2,921. In the statutory notice of deficiency, respondent disallowed the claimed deduction. A self-prepared statement attached to petitioners' return reveals that the total amount claimed and disallowed for utility expenses includes $1,025.30 for "TELEPHONE" and $1,253.70 for "FAX". Petitioners had two telephone lines at their personal residence. The first telephone line was used primarily for personal purposes.3 Petitioner husband alleges that the second telephone line (line 2) was used only for business purposes. According to petitioner husband, line 2 was used to make both telephone calls and facsimile transmissions in connection with various projects which he worked on during 1992. Although we believe that petitioner husband used line 2 for business purposes during 1992, we are not convinced that it was used exclusively for business purposes. After considering petitioner husband's testimony and reviewing his telephone records, we estimate that $250 of the charges for 1992 were business related. See Cohan v. Commissioner, 39 F.2d 540, 543- 544 (2d Cir. 1930). Petitioners have presented no evidence with respect to their other claimed utility expenses. Accordingly, we 3 The cost of basic service on the first telephone line is rendered nondeductible by sec. 262(b).Page: Previous 1 2 3 4 5 6 Next
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