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After concessions by the parties,1 the issues for decision,
all of which involve the substantiation of deductions claimed by
petitioner on his Schedule C, are as follows:
(1) Whether petitioner is entitled to a deduction for
depreciation on his automobile. We hold that he is not.
(2) Whether petitioner is entitled to a deduction for
cellular telephone expense. We hold that he is not.
(3) Whether petitioner is entitled to a deduction for
educational expense. We hold that he is not.
(4) Whether petitioner is entitled to a deduction, in excess
of the amount allowed by respondent in the notice of deficiency,
for business use of home. We hold that he is not.
Adjustments in the notice of deficiency relating to self-
employment tax under section 1401 and the deduction under section
164(f) for one-half the self-employment tax are mechanical
matters.2 The resolution of these adjustments depends solely on
1 Petitioner concedes that he failed to include $305 of
interest income from Chase Bank on his return. Respondent
concedes that petitioner is entitled to the deduction for “Davis
Petroleum expenses” as claimed by petitioner on Schedule C. The
parties agree that petitioner is entitled to a Schedule C
deduction for tax preparation fees in the amount of $198, rather
than $248 as claimed. (The parties also agree that petitioner is
entitled to a Schedule A deduction for tax preparation fees in
the amount of $127; however, that deduction will have no tax
effect if petitioner’s itemized deductions do not exceed the
standard deduction.) Finally, respondent concedes that the
examination of petitioner’s tax return began after July 22, 1998.
2 Unless otherwise indicated, all section references are to
(continued...)
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