Christopher D. and Kristie M. Farran - Page 19

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          International Airport dated February 25, 2003, to support their             
          deduction for supplies.  It is unclear whether they want to also            
          assert that the $5 was part of the $8 claimed for parking.  If              
          this amount is for parking, it is unclear whether the amount paid           
          was a nondeductible commuting cost.  Without more of an                     
          explanation, petitioners are not entitled to deduct any amount              
          for parking expenses in 2003.                                               
               Petitioners claimed $26 for professional publications in               
          2003.  Mr. Farran testified that this amount represented books              
          that he needed for his classes at Dakota County Technical                   
          College.  Petitioners have introduced no documentation or                   
          substantiation of this expense, however.  We conclude that                  
          petitioners are not entitled to deduct the $26 for professional             
          Expenses Subject to Strict Substantiation Requirements                      
               We now consider those expenses that are subject to the                 
          additional strict substantiation requirements under section                 
          274(d).  Expenses subject to strict substantiation may not be               
          estimated under the Cohan rule.  Sanford v. Commissioner, 50 T.C.           
          at 827.                                                                     
               Cellular Phone Expenses                                                
               Petitioners claimed $372 for cellular phone expenses for               
          2003.  Cellular phones are included in the definition of “listed            

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