Juvy Lyn Andrade Te Eng Fo - Page 13




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          satisfy the strict substantiation requirements under section                
          274(d).  Accordingly, and on the basis of the foregoing, we hold            
          that petitioner is not entitled to deduct any cellular phone                
          expenses under the listing of “instrument/equipment” for taxable            
          year 2002.                                                                  
               Finally, and with respect to the unreimbursed employee                 
          expenses for books/journals/magazines, job-seeking expenses, and            
          business gifts, petitioner provided no credible evidence                    
          whatsoever substantiating that she did, in fact, actually incur             
          these costs.  First, petitioner did not provide any titles of               
          journals or books or periodicals or any documentary evidence that           
          she actually incurred the expenses claimed.  Second, and with               
          respect to the $1,868 of job-seeking expenses disallowed by                 
          respondent, petitioner did not provide any credible evidence                
          showing that she incurred the job-seeking expenses claimed on her           
          2002 return.  Although petitioner did testify that she flew to              
          New York City for interviews, she admitted that these trips were            
          for personal pleasure and that she did not always make these                
          trips for primarily job-seeking reasons.  For example, petitioner           
          candidly admitted that one of the trips was actually made for the           
          purpose of attending a funeral.  Finally, petitioner produced               
          only one receipt for a bottle of cologne to substantiate the                
          $1,747 business gifts expense included in unreimbursed business             
          expenses on her Schedule A.  We are unconvinced that the expense            







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