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any documents to support his vague and illusory testimony. We
sustain respondent’s determination.
4. Commissions and Fees
Petitioner deducted $1,194 for commissions and fees. At
trial, petitioner testified that he paid clients referral fees
for new clients. Petitioner did not present any documents or
other evidence as to this deduction. Petitioner failed to
provide the Court with evidence sufficient to establish a
rational basis upon which an estimate can be made. We sustain
respondent’s determination.
5. Depreciation
Petitioner deducted $2,403 for depreciation. Petitioner did
not attach a Form 4562, Depreciation and Amortization, to his
Federal income tax return. At trial, petitioner submitted a list
entitled “Schedule C Depreciation”. Petitioner depreciated two
computers, a laser printer, a calculator, a fax machine, various
pieces of furniture, and a Mercedes. For the reasons previously
stated, petitioner is not entitled to a depreciation deduction
for his Mercedes.
Of the items listed on the schedule, only some of the
furniture and one of the computers, an Apple Macintosh LC III,
were purchased in 1994. A computer is a listed property under
section 280F(d)(4)(iv), and a taxpayer must meet the strict
substantiation requirements of section 274(d). Petitioner
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