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However, petitioner failed to produce records or documents to
substantiate the mileage and the amount, time, and business
purpose of the expenses paid or incurred for the car. Petitioner
also failed to produce records or documents to substantiate any
business travel, computer or peripheral equipment, or a cellular
telephone. Consequently, petitioner is disallowed a deduction
for any of these expenses. See sec. 274(d); Shea v.
Commissioner, 112 T.C. 183, 187 (1999); Smith v. Commissioner, 80
T.C. 1165, 1171 (1983); Gaylord v. Commissioner, T.C. Memo. 2003-
273; Boler v. Commissioner, T.C. Memo. 2002-155; Wilson v.
Commissioner, T.C. Memo. 2001-301; sec. 1.274-5T, Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
With respect to section 280A expenses, petitioner made only
uncorroborated approximations. Petitioner testified that he
recalled the rent to be approximately $1,150 per month, estimated
electricity bills at an average of $80 per month, gas bills
estimated at $54 per month, and an estimated $200 per month for
telephone bills. Petitioner admitted that these expenses were
for his residence but also claimed he did business out of his
home. However, there is no evidence in the record that any part
of petitioner’s home was used exclusively and regularly for
business or otherwise qualifies for an exception from the general
rule of section 280A disallowing expenses of a dwelling unit used
by the taxpayer as a personal residence. Therefore, petitioner
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