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business purposes, nor did she apportion the expenses between
personal and business use. Section 262(b) disallows any
deduction for basic telephone service as a personal expense.
Because the record does not provide a reasonable basis for
estimating the amount attributable to business purposes, see
Vanicek v. Commissioner, supra, respondent’s determination on
this issue is sustained.
E. Rent or Lease of Other Business Property
Petitioner claimed a $472 deduction for rent or lease of
other business property which respondent disallowed in full.
Petitioner did not identify the property in question or how it
relates to a trade or business. Respondent’s determination on
this issue is sustained.
F. Repairs and Maintenance
Petitioner claimed a $700 deduction for repairs and
maintenance which respondent disallowed in full, but petitioner
introduced no evidence to support the claimed deduction.
Respondent’s determination on this issue is sustained.
G. Car and Truck Expenses
Section 274(d) imposes strict substantiation requirements
for listed property, travel, entertainment, and meal expenses.
Sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985). Listed property generally includes passenger
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Last modified: November 10, 2007