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the payments. Respondent does challenge the nature of the
telephone calls. Petitioner presented regular telephone records
from April, May, and June of 1993, bearing notations of the calls
which were business in nature. Petitioner presented cellular
phone records from July to December of 1993 indicating the time,
amount, and place of the calls. Cellular phones are classified
as “listed property” under section 280F(d)(4)(A)(v), and such
expenses must be substantiated by adequate records or sufficient
evidence which corroborate the taxpayer's own testimony,
including: (1) The amount of the expenditure or use based on the
appropriate measure; (2) the time and place of the expenditure or
use; and (3) the business purpose of the expenditure or use. See
sec. 274(d). Petitioner testified that the business purpose of
the calls related to legal matters and the affairs of Cilena, as
well as the dissolution of Aeternum. We hold that petitioner has
established entitlement to a deduction for the regular telephone
and cellular phone expenses incurred.
G. Security
Petitioner claimed a deduction of $2,394 for security
antitheft services related to the protection of the rental
equipment. Private security payments to protect property which
is subject to potential loss or destruction arising from the
operation of a business are deductible expenses under section
162(a). See Munson v. Commissioner, 18 B.T.A. 232, 236-237
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