Bamidele Arike Kolapo - Page 8

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          traveled for purposes of her claimed deduction.  Given the                  
          contradictory nature and general unreliability of petitioner’s              
          testimony and the evidence produced, we find that petitioner has            
          failed to substantiate her 2003 and 2004 vehicle expenses.                  
               Next, we must address petitioner’s cleaning expenses.                  
          Petitioner provided no receipts to substantiate her cleaning                
          expenses.  As we have already established, petitioner’s logs are            
          unreliable and insufficient to substantiate those expenses.                 
          Additionally, petitioner failed to show that she was required to            
          wear a uniform to work, thus failing to prove that her cleaning             
          expenses met the ordinary and necessary business requirement                
          under section 162.  Accordingly, we sustain respondent’s                    
          determination to disallow petitioner’s deduction for her cleaning           
               We must next address petitioner’s cell phone expenses.  As a           
          general rule, section 262 prohibits a deduction for expenses that           
          are personal in nature.  The prohibition of section 262 regarding           
          the deductibility of personal expenses takes precedence over the            
          allowance provision of section 162, Sharon v. Commissioner, 66              
          T.C. 515, 522-525 (1976), affd. 591 F.2d 1273 (9th Cir. 1978),              
          and a taxpayer must demonstrate that the expenses at issue were             
          different from or greater than what he would have spent for                 
          personal purposes, Sutter v. Commissioner, 21 T.C. 170, 173-174             

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