Tobias G. Ogu - Page 18

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          or the unsupported testimony of the taxpayer.  E.g., Golden v.              
          Commissioner, T.C. Memo. 1993-602.  In other words, in the                  
          absence of adequate records or sufficient evidence corroborating            
          the taxpayer’s own statement, any deduction that is subject to              
          the stringent substantiation requirements of section 274(d) is              
          proscribed.  These stringent substantiation requirements are                
          designed to encourage taxpayers to maintain records, together               
          with documentary evidence substantiating each element of the                
          expense to be deducted.  Sec. 1.274-5T(c)(1), Temporary Income              
          Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).                               
               In addition to the strict substantiation requirements of               
          section 274(d), a deduction for foreign travel is subject to the            
          allocation requirements of section 274(c).  E.g., Shackelford v.            
          Commissioner, T.C. Memo. 1995-484; Hilton v. Commissioner, T.C.             
          Memo. 1990-11.  Thus, section 274(c) generally requires the                 
          proration of foreign travel expenses between business and                   
          nonbusiness expenses.                                                       
               With the foregoing general principles in mind, we turn now             
          to the specific Schedule C deductions in issue.                             
               2.  Depreciation, Office Furnishings, EDI Fee, etc.                    
               On his Schedule C for 1999, petitioner claimed a deduction             
          for “EDI fee, advertising, telephone, etc.” in the amount of                
          $9,113; of this amount, respondent allowed $1,489 and disallowed            
          the balance.  On his Schedule C for 2000, petitioner claimed a              
          deduction for used file cabinets, chairs, and tables in the                 






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