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taxpayer, a mere bookkeeping entry of the item does not suffice
without proof of further substantiation. Consolidated-Hammer Dry
Plate & Film Co. v. Commissioner, 49 T.C. 153, 171 (1967), affd.
409 F.2d 1077 (7th Cir. 1969). Petitioner produced no books and
records, receipts, or any other documentation to substantiate
these expenses. She testified that, although she received
receipts for many of the expenses claimed, at the time of
purchase, she did not retain such receipts, nor did she maintain
books and records of her expenses.
The Court notes that, even if petitioner had substantiated
her expenses, some of the expenses claimed are not deductible.
For example, the $780 claimed for Windsor-Detroit Tunnel fees
likely was incurred as petitioner’s expenses in commuting to and
from her home and her places of employment. Commuter expenses
are considered personal expenses and are not deductible. Sec.
262(a). The Court also recognizes, however, that petitioner
incurred deductible expenses for which she may not have been
reimbursed, such as long-distance telephone calls, licenses and
dues as a registered nurse, fees for conferences she may have
been required to attend, uniforms, certain equipment, other
medical devices, and items of that nature. The Court is
satisfied that petitioner incurred such expenses. The Court is
empowered to make an allowance for such expenses in “as close an
approximation as * * * [we] can, bearing heavily if * * * [we]
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