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comply with the substantiation requirements of section 274(d).
Accordingly, we sustain respondent’s determination with respect
to these deductions.
4. Cellular Phone Expenses
Petitioner disputes respondent’s denial of $1,842 in
cellular phone expenses she incurred in 1999.
Cellular phones are included in the definition of “listed
property” for purposes of section 274(d)(4) and are thus subject
to the strict substantiation requirements of this section.
In support of her claim for deductions, petitioner presented
copies of 10 checks, drawn on her account for a total of $1,842.
Six of the checks were made payable to “Bell Atlantic Mobile” and
“C-work Solutions”, while the remaining four were made payable to
a specific individual. Petitioner testified that the recipient
of the latter payments was her sister, whose phone she was using
during that time. Even if we were to believe petitioner’s
assertions, which we do not, petitioner has produced no evidence
that the phone was used for business purposes or any other
reliable evidence regarding the services rendered. Given
petitioner’s failure to substantiate the cellular phone expenses,
we sustain respondent’s determination denying these deductions.
5. Utilities
Petitioner claimed deductions for utilities used in her home
office for both 1999 and 2000. After concessions by petitioner
at trial, the amount that remains in contention is $497 incurred
during 1999.
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Last modified: May 25, 2011