Alan L. Levitt - Page 18




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         unsupported, self-serving testimony to be credible.  Niedringhaus            
         v. Commissioner, supra; Tokarski v. Commissioner, supra.                     
         Therefore, petitioner is not entitled to a deduction for the                 
         storage unit.                                                                
                   9.  Repairs                                                        
              Petitioner deducted $431 for repairs and maintenance.                   
         Respondent conceded that petitioner is entitled to deduct $110.              
         The repairs relate to petitioner’s printer.  Petitioner                      
         substantiated $270.31 for repairs, and he is entitled to a                   
         deduction in that amount.                                                    
              One of the repair receipts relates to “Clickart Company”                
         software.  The record does not indicate how this software is                 
         related to petitioner’s trade or business.  Therefore, petitioner            
         is not entitled to a deduction for the software.4                            
                   10.  Supplies                                                      
              Petitioner deducted $306 for supplies.  At trial, petitioner            
         testified as follows: “Office supplies would have been fax paper,            
         basically the--maybe the toner for the fax machine.  Things like             
         that.”  Petitioner did not provide documents or other evidence               
         regarding supplies.  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.                

               4  Even if the software related to petitioner’s trade or               
          business, he would not be entitled to a current deduction for the           
          full amount.  Secs. 167(f)(1), 197(d).                                      





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