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expenses were different from or were in excess of what he would
have spent for personal reasons. In addition, petitioner has not
offered any evidence to substantiate his remaining employee
business expenses.
Accordingly, respondent’s determination disallowing
petitioner’s employee business expenses, to the extent not
conceded, is sustained.
B. Deductions Claimed on Schedule C
Under section 162, a taxpayer may deduct all ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business if the taxpayer maintains
sufficient records to substantiate the expenses. Sec. 162(a);
see sec. 6001; Deputy v. du Pont, 308 U.S. 488, 495 (1940).
1. Expenses Required To Be Substantiated Under
Section 274(d)
In addition to satisfying the criteria for deductibility
under section 162, certain categories of expenses must also
satisfy the strict substantiation requirements of section 274(d)
before those expenses will be allowed as deductions. See secs.
274(d), 280F(d)(4). Expenses subject to the strict
substantiation requirements of section 274(d) include passenger
automobiles, meals and entertainment, traveling, and cellular
telephones. Secs. 274(d), 280F(d)(4)(A)(i), (v).
The taxpayer must substantiate the amount, time, place, and
business purpose of the expenditures and must provide adequate
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