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support of deductions for the other line. Moreover, the records
do not distinguish whether the telephone charges were for local
or long distance service.
The magnitude of the telephone expenses petitioner seeks to
deduct suggests to us that significant long-distance charges are
included in the figure. The documentation proferred by
petitioner generally does not indicate what portion of the
charges was for long-distance, nor has she proven a business
purpose for significant long-distance charges. However, we are
persuaded that petitioner’s escort business almost certainly
involved the use of local telephone service to arrange
appointments. In these circumstances, we allow a deduction of
$600 for local telephone expenses at the locations where she
conducted her escort business during 1989. See Cohan v.
Commissioner, supra.
The deduction of other claimed expenses for 1989 requires
closer examination. The allowance of travel and entertainment
business deductions described in section 274 are subject to
strict rules of substantiation. Section 274(d) provides that,
unless the taxpayer complies with these rules, no deductions
shall be allowed with respect to “any traveling expense
(including meals and lodging away from home),” or “for any item
with respect to an activity which is of a type generally
considered to constitute entertainment”. The rules require the
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