- 14 -
Certain business expenses may not be estimated because of
the strict substantiation requirements of section 274(d). See
sec. 280F(d)(4)(A); Sanford v. Commissioner, 50 T.C. 823, 827
(1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969). For such
expenses, only certain types of documentary evidence will
suffice.
Job Search Expenses
We now examine those expenses not subject to the strict
substantiation requirements, beginning with job search expenses.
Petitioners claimed $156 for job search expenses during 2003.
The parties stipulated that Mr. Farran incurred $119.43 of
job search expenses. Petitioners introduced a bank statement,
receipts, and two bills to support their claim to the additional
amount for job search expenses. Many of the documents
petitioners submitted are illegible, however, and do not
establish that these amounts were actually incurred in connection
with Mr. Farran’s job search. We therefore conclude that
petitioners are entitled to deduct only the $119.43 of agreed
upon job search expenses.
Internet Access Expenses
Petitioners claimed $264 for Internet access expenses during
2003. We have characterized Internet expenses as utility
expenses. Verma v. Commissioner, T.C. Memo. 2001-132. Strict
substantiation therefore does not apply, and we may estimate the
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: November 10, 2007