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used, he said it was for writing "bills", writing proposals, and
investigating new techniques. Upon further questioning he stated
that there were no proposals written for the year and that the
office was used mainly for writing "bills" and for "personal e-
mail to send bills" rather than to mail them.
Petitioner also testified that he used his garage as a
storage facility for his "business items". He presented pictures
of the interior and exterior of his garage. The pictures of the
interior show a mixture of items that could be used for
petitioner's trade or business or for personal purposes.
The Court finds by a preponderance of the evidence that
petitioner used his dining room and his garage only occasionally
and not exclusively or on a regular basis as the principal place
of business for his trade or business.
Deductions for Business Transportation Expenses
and Computer Expenses
Where a taxpayer has established that he has incurred a
trade or business expense, failure to prove the exact amount of
the otherwise deductible item may not be fatal. Generally,
unless precluded by section 274, the Court may estimate the
amount of such an expense and allow the deduction to that extent.
See Finley v. Commissioner, 255 F.2d 128, 133 (10th Cir. 1958),
affg. 27 T.C. 413 (1956); Cohan v. Commissioner, supra. Certain
business deductions described in section 274, however, are
subject to rules of substantiation that supersede the doctrine in
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