- 15 - cards at that time, so I had to go out and purchase business cards on my own.” Petitioner also testified that he may have attended two training sessions in 2003 and that he purchased a briefcase to carry materials back from a training session in Georgia. He did not specify when he bought the briefcase. We are not convinced that petitioner purchased these items in 2003, particularly given the short shelf life of any INS business cards printed in 2003, see supra note 8. We do not accept petitioner’s testimony as a reasonable basis to estimate a 2003 deduction for these expenses, in the absence of documentary proof that petitioner actually purchased the business cards and briefcase in 2003. Respondent’s determination as to the claimed business card and briefcase expense deductions is sustained. Cellular Telephone Petitioner claimed a deduction of $875 for cellular telephone expenses in 2003. Petitioner asserted that he incurred these charges making work-related calls when on overtime assignments. Petitioner did not offer any receipts, bills, or other documentary support for these expenses. Petitioner has failed to meet the strict substantiation requirements required by sections 274(d) and 280F(d)(4)(A)(v) for 8(...continued) obsolete by March of 2003, since petitioner worked for a different organization at that point. See supra note 2.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008