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the production of that income. The “Amended 2003 Schedule ‘C’”
that petitioner submitted at trial, see supra note 3, was prepared
shortly before trial and represents a reconstruction of expenses
petitioner believed he paid. Amounts shown on the Schedule C were
revised at trial to show a rent expense of $5,369,7 a
mileage/travel expense of $5,546.50, and a misc./membership
expense of $150.
Petitioner testified that although he used portions of his
dwelling for purposes of meeting clients for the first 9 months of
2003, he neither owned nor paid rent for the premises. Moreover,
he did not pay specifically for utilities, telephone, or Internet
services. Rather, he contributed to the general upkeep of the
home, where he resided with his wife. The amount he determined
deductible as rent was the amount that he theoretically would have
paid for that portion of the home he used for his consulting
activities had there been a third-party landlord, as well as a
portion of the utilities, telephone, and Internet services that
were allocable, in petitioner’s view, to his consulting
activities. Petitioner did not submit any documentary
substantiation (such as utility bills or telephone bills) in
support of his claimed deduction for expenses paid in using a
portion of his home for his consulting activities.
7Petitioner clarified that $5,369 represents the total
amount for rent, utilities, telephone, and Internet services.
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