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A taxpayer may deduct ordinary and necessary advertising
expenses related to the taxpayer’s trade or business. RJR
Nabisco, Inc. v. Commissioner, T.C. Memo. 1998-252. Other than
petitioner’s general testimony regarding advertising, petitioner
failed to provide a rational basis upon which we can base an
estimate as to the amount petitioner paid for advertising.
Petitioner submitted a Christmas card and a past due invoice for
the pens. The record does not indicate that petitioner in fact
paid the delinquent amount. Therefore, petitioner is entitled to
deduct $201.87 for advertising.
3. Car and Truck Expenses
Petitioner deducted $6,965 for car and truck expenses.
Petitioner owned a Mercedes, and he testified that he drove it
between Reno, Las Vegas, and Beverly Hills. Petitioner claimed
that he maintained a travel diary, but he did not present it at
trial. Petitioner did not present any receipts at trial
regarding his car and truck expenses.
Listed property includes passenger automobiles. Sec.
280F(f)(4)(A)(i). Petitioner therefore must meet the strict
requirements of section 274 to be entitled to a deduction related
to car expenses. Petitioner failed to establish the amount of
the expense, the time and place of each use, and the business
purpose of the use of the Mercedes. Petitioner did not provide
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