N. Joseph Calarco - Page 26

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          documentation issues, however, are merely elements of the                   
          ultimate determinative factor--petitioner has not met his burden            
          under sections 274 and 280F for substantiating entertainment                
          expenses.                                                                   
          12. Telephone                                                               
               Section 262 provides that the first phone line into a                  
          taxpayer’s home is not deductible.  Petitioner thus is unable to            
          deduct expenses relating to his phone line, absent a showing that           
          there was some service or feature of the line dedicated to his              
          business activities, a showing he did not make.  Cf. Popov v.               
          Commissioner, T.C. Memo. 1998-374, revd. on other grounds 246               
          F.3d 1190 (9th Cir. 2001).                                                  
          13. Miscellaneous Cash                                                      
               We are not required to accept self-serving testimony from              
          petitioner regarding his estimates of cash spent on his                     
          activities.  Even were we to accept his assertion of how much               
          cash he spent, we still would not be convinced that those amounts           
          went to business, as opposed to personal, expenses.  Thus, we               
          disallow the deduction of these amounts.                                    
          14. Periodicals                                                             
               On petitioner’s Schedule C, he claimed a deduction for                 
          $1,055 in periodical expenses.  This entire amount is documented            
          in his posttrial submission.  The documentation, however, shows             
          that $838 of this total was spent on subscriptions to major                 






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