- 35 - are section 280F(d)(4) “listed property”.24 These items, as previously stated, require strict substantiation. Here, petitioners failed to detail the expenses denied, the amounts of those expenses, and the business purpose for those expenses. We are not required to, and shall not, guess. Petitioners have failed to substantiate sufficiently the expenses claimed in excess of the amount respondent allowed in the notice of deficiency. Furthermore, petitioner’s vague testimony that all the expenses claimed were for business purposes is not sufficient. “It is well settled that we are not required to accept petitioner’s self-serving testimony in the absence of corroborating evidence.” Jacoby v. Commissioner, T.C. Memo. 1994-612 (citing Lerch v. Commissioner, 877 F.2d 624, 631- 632 (7th Cir. 1989), affg. T.C. Memo. 1987-295); see Geiger v. Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159; Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992). “There must be sufficient evidence in the record to permit the Court to conclude that a deductible expense was incurred in at least the amount allowed.” Jacoby v. Commissioner, supra (citing Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957)) (emphasis added). To permit 24Petitioner testified that part of the deductions claimed and disallowed were for computer equipment and cellular telephone. See sec. 280F(d)(4)(A)(v); Vaksman v. Commissioner, T.C. Memo. 2001-165; Nitschke v. Commissioner, T.C. Memo. 2000- 230.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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