Robert A. White - Page 16

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          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           

          obsolete by March of 2003, since petitioner worked for a                    
          different organization at that point.  See supra note 2.                    

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