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“listed property” is defined in section 280F(d)(4) to include
cellular telephones. Sec. 280F(d)(4)(A)(v). Although, as
required by section 274(d)(4), petitioner substantiated the
respective amounts of the cellular telephone expenses that he
paid during 1991 and 1992, on the instant record, we find that
petitioner has failed to show that he satisfies the remaining
substantiation requirements of section 274(d)(4) and the regula-
tions thereunder. Petitioner did not introduce into evidence
adequate records to satisfy those requirements. Consequently,
petitioner may satisfy those requirements only by introducing
into the record in this case sufficient evidence corroborating
his own statements. Sec. 274(d)(4); sec. 1.274-5T(c)(1), Tempo-
rary Income Tax Regs., 50 Fed. Reg. 46016-46017 (Nov. 6, 1985).
As discussed above, petitioner relies on his self-serving testi-
mony to support his contention that the cellular telephone
expenses at issue constitute 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 intro-
ducing into the record in this case sufficient evidence corrobo-
rating his statements with respect to his alleged business use of
his cellular telephone lines during 1991 and 1992. On the record
before us, we find that petitioner has failed to carry his burden
of establishing that he satisfies all of the substantiation
81(...continued)
the expense or other item * * *.
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