- 12 - 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Petitioner failed to do so. Accordingly, respondent’s determination regarding expenses subject to section 274, as modified by his concessions, is sustained. 10. Computer, Fax, and Printer At trial, petitioner tried to establish she is entitled to deduct as expenses computers, faxes, and printers. Section 274(d) applies to, among other things, computer and peripheral equipment; however, there is an exception for such equipment used exclusively at a regular business establishment and owned or leased by the person operating such establishment. Secs. 274(d)(4), 280F(d)(4)(A)(iv), (B). Regardless of whether section 274 applies or not (some of the computers and peripheral equipment were at petitioner’s nursing business office, and some were at the homes of petitioner’s contractors), the evidence does not establish when the computers, faxes, and printers were purchased or how much they cost. As there is insufficient evidence to establish these items were purchased during the years in issue, or if they were so purchased a rational basis for making an estimate, we shall not allow petitioner a deduction for these items. See Cohan v. Commissioner, supra at 543-544; Vanicek v. Commissioner, supra at 742-743; see also secs. 274(d), 280F(d)(4)(A)(iv), (B).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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