Leonard Stockwell - Page 13




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          Internet Access Expenses                                                    
               We now examine those expenses not subject to the strict                
          substantiation requirements.  Petitioner claimed $210 for                   
          Internet access expenses during 2003.  We have characterized                
          Internet expenses as utility expenses.  Verma v. Commissioner,              
          T.C. Memo. 2001-132.  Strict substantiation therefore does not              
          apply, and we may estimate the business portion of utility                  
          expenses under the Cohan rule.  See Pistoresi v. Commissioner,              
          T.C. Memo. 1999-39.                                                         
               Petitioner introduced copies of credit card statements                 
          indicating that Microsoft charged him a total of $109.75 in 2003.           
          The Microsoft charges were incurred in August through November              
          2003, months when he was in Milwaukee, Wisconsin, and Detroit,              
          Michigan.  Petitioner admitted that he did not have documentation           
          that his employer, NWA, required him to have Internet access.               
          Petitioner testified that he used the Internet to look up                   
          information about his health insurance.                                     
               Petitioner has not proven that his employer required him to            
          have Internet service or that he used the Internet for his work             
          at NWA.  Petitioner is therefore not entitled to deduct any                 
          Internet access expenses as employee business expenses for 2003.            
          Cleaning Expenses for Uniforms                                              
               Petitioner claimed $722 for cleaning expenses for his NWA              
          uniforms.  Expenses for uniforms are deductible if the uniforms             







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