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amount of allowable deductions based on the evidence and our view
as to the credibility of the witnesses. Feingold v.
Commissioner, T.C. Memo. 1956-214. We find that petitioner is
entitled to deduct 40 percent of the $2440.25 in this category
that has not otherwise been specifically addressed.
8. “Business Cellular”
Under section 280F(d)(4)(A)(v), cellular phones are listed
property and thus subject to the heightened substantiation
requirements of section 274, which petitioner has failed to meet.
This category of deductions is entirely disallowed.
9. Internet
Petitioner has offered no evidence of his business use of
the Internet. We infer from his electronic banking records that
he used the internet to track his business (and personal)
expenses. This Court has previously characterized internet
expenses as utility expenses. Verma v. Commissioner, T.C. Memo.
2001-132. Under the Cohan rule we may estimate the business
portion of utility expenses. See Pistoresi v. Commissioner, T.C.
Memo. 1999-39. We estimate that 20 percent of his internet
expenses were business-related.
10. Software
There are $267.48 in software expenses listed in
petitioner’s posttrial submission. Of this amount, $82 appears
to have been for multimedia programming, and we are satisfied
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