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with documentary evidence substantiating each element of the
expense sought to be deducted. Sec. 1.274-5T(c)(1), Temporary
Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
Petitioners submitted copies of Ameritech phone bills for
1998 that contain summary information on petitioner's telephone
charges but give no detail on the nonbasic and larger charges
included in the total bill. For example, each bill shows a
monthly service charge, and separate charges for local and long
distance service, and for taxes. For some months, the bills
show separate charges for internet service and for paging. Still
other monthly bills show, in some cases, hundreds of dollars of
charges for which there is no explanation. The face of the bill
states: "For Detailed Charges - See Page 3". There is,
however, no page 3 available for any of the bills. With respect
to what the Court assumes from petitioners' testimony may be cell
phone charges, there is nothing in the record meeting the
requirements of sec. 1.274-5T(c)(1), Temporary Income Tax Regs.,
50 Fed. Reg. 46016 (Nov. 6, 1985). If the charges were other
than cell phone charges, petitioners have failed to offer any
explanation or any substantiation for them.
Petitioners, for the real estate business phone, paid
$1,148.15 for monthly service charges, and separate charges for
local and long distance service, taxes, internet service, and
paging. The Court finds that petitioners have failed to properly
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