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The deduction for cell phone and beeper expenses is subject
to the same strict substantiation requirements as the car
expenses, as discussed above. Secs. 274(d), 280F. Petitioners’
failure to substantiate the expense by original or reasonably
reconstructed records is grounds for disallowing the deduction.
Again, we think it highly unlikely that respondent allowed any
portion of the deduction for cell phone and beeper expenses.
The remaining items included in the deduction for “Other
expenses” total slightly more than the $707 allowed by
respondent. That being the case, it appears that respondent has
already allowed, in the absence of substantiating records, the
majority of these items. We find no basis in the record for
increasing that amount.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011