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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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Last modified: November 10, 2007