Leonard Stockwell - Page 16




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          amount of business use and the amount of total use for the                  
          property to substantiate the amount of expenses for listed                  
          property.  Nitschke v. Commissioner, T.C. Memo. 2000-230; sec.              
          1.274-5T(b)(6)(i)(B), Temporary Income Tax Regs., 50 Fed. Reg.              
          46016 (Nov. 6, 1985).  Expenses subject to strict substantiation            
          may not be estimated under the Cohan rule.  Sanford v.                      
          Commissioner, 50 T.C. at 827.                                               
               Petitioner did not prove that NWA required him to have a               
          cellular phone.  Petitioner provided an NWA employee telephone              
          listing and copies of his cellular phone bills.  The NWA employee           
          telephone listing indicates only that petitioner’s cellular phone           
          number was the contact number he gave NWA, not that NWA required            
          him to have a cellular phone.  Petitioner also did not offer any            
          evidence indicating how much he used his cellular phone for                 
          business use and how much for personal use.  Petitioner failed to           
          establish that he incurred any expenses to use his cellular phone           
          for business purposes in addition to those he would have incurred           
          had he used it only for personal purposes.  Petitioner is                   
          therefore not entitled to deduct any cellular phone expenses for            
          2003.                                                                       
          Charitable Contributions                                                    
               We finally consider petitioner’s charitable contributions.             
          Petitioner claimed he contributed $225 cash and property worth              
          $924 to charitable organizations in 2003.  Charitable                       







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