- 14 - Petitioners argue that the expenses incurred in making these purchases are deductible under section 179. A taxpayer may elect to expense, rather than capitalize, certain property used in a trade or business. Sec. 179(a), (c). The election must be made on the taxpayer’s first income tax return for the taxable year to which the election applies. Sec. 179(c)(1)(B); sec. 1.179-5(a), Income Tax Regs. Petitioners did not elect to expense the computer equipment on their 1996 return. Therefore, they are not entitled to a deduction for the equipment under section 179. Furthermore, we find that petitioners are not entitled to any other deduction for the equipment because petitioners have not substantiated the business versus personal usage of the computer equipment, as required under section 274(d), discussed supra. For the same reason, petitioners are not entitled to deductions for the rental of a scan converter and other computer equipment, or for their subscription to Compuserve online service. See sec. 274(d). Travel expenses and professional licenses Mr. Brayshaw testified that he incurred numerous deductible expenses in business-related travel. He provided receipts as substantiation. The receipts, standing alone, do not provide the level of substantiation which is required under section 274(d). However, Mr. Brayshaw was able to explain certain of the receipts at trial in great enough detail to provide adequatePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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