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petitioner has failed to carry his burden of establishing that
the home telephone expenses of $1,393.24 and $1,059.27 that he
paid during 1991 and 1992, respectively, constitute ordinary and
necessary business expenses paid in carrying on his Schedule C
business.
With respect to the cellular telephone expenses at issue for
1991 and 1992, the disputes between the parties with respect to
the deductibility of those expenses are whether petitioner, who
we have found paid those expenses during those years, has estab-
lished (1) that he paid those expenses during those years in
carrying on his Schedule C business and (2) that he satisfies the
substantiation requirements of section 274(d)(4). As to the
parties’ first dispute, petitioner relies on his self-serving
testimony to support his contention that the cellular telephone
expenses at issue are ordinary and necessary expenses paid in
carrying on his Schedule C business. We are not required to, and
we shall not, rely on that testimony. On the instant record, we
find that petitioner has failed to carry his burden of showing
that the telephone expenses of $729.28 and $903.92 that he paid
during 1991 and 1992, respectively, for his cellular telephone
lines represented expenses paid solely for his cellular telephone
line that was supposed to be used for business purposes. Even if
petitioner had made such a showing, on the instant record, we
find that petitioner has failed to carry his burden of showing
that he used his cellular telephone line that was supposed to be
used for business purposes solely in carrying on his Schedule C
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