Sharon T. Myrick - Page 10




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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