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investments. Petitioners did not keep receipts for the purchase
of the financial publications.
The cost of a daily newspaper of general circulation is
generally nondeductible. Wheeler v. Commissioner, T.C. Memo.
1984-425. Petitioners also have not introduced any receipts for
the other financial publications and thus have not substantiated
expenses for these publications. We conclude that petitioners
are therefore not entitled to any deduction for publications in
2003.
Expenses Subject to Strict Substantiation Requirements
We now consider those expenses that are subject to the
additional strict substantiation requirements under section
274(d). Expenses subject to strict substantiation may not be
estimated under the Cohan rule. Sanford v. Commissioner, supra
at 827.
Cellular Phone Expenses
Petitioners claimed $1,668 for cellular phone expenses for
2003. Cellular phones are included in the definition of “listed
property” for purposes of sections 274(d)(4) and 280F(d)(4)(A)(v)
and are thus subject to the strict substantiation requirements.
Gaylord v. Commissioner, T.C. Memo. 2003-273. A taxpayer must
establish the amount of business use and the amount of total use
for the property. Nitschke v. Commissioner, T.C. Memo. 2000-230;
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