James A. and Joan H. Soholt - Page 11




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          an approximation.  Vanicek v. Commissioner, 85 T.C. 731, 742-743            
          (1985).  Without such a basis, any allowance would amount to                
          unguided largesse.  Williams v. United States, 245 F.2d 559, 560            
          (5th Cir. 1957).                                                            
               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                   
          suffice.                                                                    
          Unreimbursed Employee Business Expenses Not Subject to Strict               
          Substantiation                                                              
               We first consider the unreimbursed employee business                   
          expenses not subject to the strict substantiation requirements.             
          We then examine those employee business expenses that are subject           
          to the additional strict substantiation requirements.                       
          Business Use of the Home                                                    
               Petitioners claimed $4,190 miscellaneous expenses for                  
          business use of their home during 2003.  Expenses for business              
          use of a taxpayer’s home are deductible only under very limited             
          circumstances.  The taxpayer must show that the portion of the              
          home purported to be used for business was exclusively used on a            











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