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does not meet the substantiation requirements of section 274
because it does not show mileage traveled, route taken, or
business purpose of these expenses. Sec. 274(d).
As to petitioner’s other Schedule C deductions, including
utilities expense, cable expense, and bank charges, petitioner
testified that she did not know how these deductions were
calculated. She did not substantiate such expenses. Therefore,
this Court holds that such deductions are not allowed and
respondent’s disallowance of such deductions is sustained.
Due to our holding that petitioner has not substantiated any
of the claimed Schedule C deductions for Port of Mystery, it is
not necessary for us to determine whether Port of Mystery was an
activity engaged in for profit.
3. Additional Tax--Section 72
Generally, section 72(t)(1) imposes a 10-percent additional
tax on early distributions from qualified retirement plans,8
unless the distribution comes within one of several statutory
exceptions. For example, distributions that are made on or after
the date on which the taxpayer attains the age of 59� are not
“early”, and therefore not subject to the 10-percent additional
tax. Sec. 72(t)(2)(A)(i). As relevant to the present case,
section 72(t)(2)(C) provides an exception for distributions “to
8As relevant to the present case, a “qualified retirement
plan” includes an individual retirement account (IRA) and a
qualified pension or profit-sharing plan. Sec. 4974(c)(1), (4).
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