Christopher D. and Kristie M. Farran - Page 14

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               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                   
          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            

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