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in issue. See sec. 274(d). Consequently, petitioner is not
entitled to any of the traveling expense deductions claimed on
the Schedules C. Respondent’s determinations in this regard are
therefore sustained.
Other types of business expenses were deducted on the
Schedules C and disallowed by respondent. Petitioner was not
entitled to reimbursement for these expenses. We find that, for
the year 1993, petitioner is entitled to deductions for these
expenses as follows:
Type of Expense Amount
Supplies $1,431
Depreciation 500
Postage 10
Taxes 60
Telephone 265
Total 2,266
Because the record does not contain adequate substantiating
evidence of business expenses that petitioner may have incurred
in 1994, or any evidence from which we can reasonably estimate
such expenses, petitioners are not entitled to any business
expense deductions for the year 1994.
Petitioner maintains that he provided services to the DOI
during the years in issue as an independent contractor. All of
the deductions here in dispute were claimed on a Schedule C as
though petitioner were not an employee of the DOI during either
year in issue.
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