James B. Clark - Page 8

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          taxpayer may deduct as moving expenses only the cost of                     
          transporting household goods and personal effects and travel,               
          including lodging but not meals, from the former residence to the           
          new residence.  Sec. 217(b).  Petitioner bears the burden of                
          proving he may deduct moving expenses.3  Petitioner did not                 
          substantiate any of the claimed moving expenses.  Petitioner                
          testified that about $20,000 of the $34,304 that he deducted as             
          moving expenses is the amount he spent to replace the roof on his           
          Idaho home.  That expense is not deductible under section 217(b).           
               2.   Business Expenses                                                 
                    a.   Telephone Expenses                                           
               Petitioner contends that he had about $11,000 in telephone             
          expenses for TAI in 2000.  He testified that telephone expenses             
          of about $11,000 were eventually paid.  Petitioner offered no               
          telephone bills showing amounts owed or bank records to show that           
          he paid any telephone bills in 2000 or at any time.  We conclude            
          that petitioner may not deduct any amount as a telephone business           
          expense for 2000.                                                           
                    b.   Internet Uplink Services Expense                             
               Petitioner testified that he paid about $47,000 to an entity           
          known as Viawest for Internet uplink services, and he contends              
          that he may deduct that amount for 2000.  We disagree.                      

               3  Petitioner does not contend (nor does the record support            
          a conclusion) that the burden of proof is shifted to respondent             
          under sec. 7491(a).                                                         




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