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.
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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Last modified: March 27, 2008