Katumba P. Kashama - Page 8

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          the amount of car and truck expenses, the Court declines to                 
          consider this evidence due to lack of credibility.                          
               The Court holds that petitioner’s car and truck expenses               
          were not properly substantiated under the cited legal authority.            
          Petitioner, therefore, is not entitled to deductions in excess of           
          amounts allowed by respondent for car and truck expenses.                   
               With respect to the amount deducted for cellular phone                 
          expenses, petitioner presented no additional receipts showing he            
          was entitled to a deduction in excess of what was allowed by                
          respondent.  In addition, petitioner offered no evidence                    
          substantiating the purchase of a computer for use in his                    
          business.  Because cellular phones and computers are listed                 
          property under section 280F(d)(4)(A), section 274(d) applies.               
          Petitioner did not meet the strict substantiation requirement of            
          section 274(d).  These two expenses, therefore, are not allowed.            
               Finally, petitioner claimed expenses for supplies, uniforms,           
          and furniture in excess of the amounts respondent allowed.                  
          Petitioner presented copies of canceled checks as the only                  
          evidence in support of these expenses.  In light of petitioner’s            
          inadequate record keeping and questionable credibility, the Court           
          declines to accept this evidence.  Therefore, respondent is                 
          sustained.                                                                  









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