- 8 -
Dugan v. Commissioner, supra (“Given that petitioner has failed
to demonstrate the business purpose for the computer expense in
accordance with section 274(d), the [section 179] deduction is
disallowed.”).
C. Office Expenses
Petitioners claim a deduction for office expenses in the
amount of $8,762.
Section 162(a) allows as a deduction “all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business”. Office expenses of the type
claimed by petitioner, e.g., postage, if paid or incurred during
the taxable year in carrying on any trade or business, can
qualify as deductible section 162(a) expenses. See sec. 1.162-
1(a), Income Tax Regs. The adequate-records-or-sufficient-
corroborating-evidence standard of section 274(d) is not
specifically applicable to such expenses. Nevertheless, a
taxpayer is required by section 6001 to keep records and to
substantiate the amounts giving rise to claimed deductions, and,
if he does not, respondent cannot be considered arbitrary or
unreasonable in denying the deductions. Roberts v. Commissioner,
62 T.C. 834, 836-837 (1974); Cook v. Commissioner, T.C. Memo.
1991-590 (citing Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976)); see sec. 1.6001-
1(a), Income Tax Regs.
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