George Thompson’s million-selling 1913 comic monologue reappears as Judge Elizabeth A. (“Tex’) Copeland provides Patricia S. Chappell,  T. C.  Sum. Op. 2024-2, filed 3/11/24, with a Cohan approximation for the cellphone use, equipment,  and “service charges” for the cellphones she and her son used in her tax prep business.

Used to be that cellphones required strict substantiation, like automobiles, but not any more since 2009. Judge Tex Copeland allows more of what Patricia paid during tax season (January through May), and part of what she paid for her son’s phone, despite a written IC agreement with son that he would pay all his own expenses. “…it is not unusual to provide cell phones to independent contractors in order for them to speak to the business’ owner and its clients.: T. C. Sum. Op. 2024-2, at p. 7, footnote 5. That lets the owner avoid call waiting while IC talks to friends on personal phone. And buying the phones invokes Section 179 expensing, even if not claimed as such.

Patricia’s vehicle expense substantiation is truly substandard, but she can show business travel from home office to satellite office, and other trips, so she gets the standard mileage for the business miles her testimony proves, based on what her cellphone software pulls via GPS.

See my blogpost “Pilot Saved by GPS,” 11/14/18, for a similar story.