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At the time they filed their petition in the instant case,
petitioners resided in Staten Island, New York. Petitioner Sita
G. Krishna (petitioner) is a medical doctor.
During taxable year 1991, petitioners received additional
income in the amount of $60,552 that they failed to report on
their Federal income tax return.
Petitioners filed their Federal income tax return for
taxable year 1991 on April 21, 1994.
OPINION
The first issue we must decide is whether petitioners are
entitled to deduct certain expenses related to petitioner's
medical practice that were not claimed on petitioners' return.
At trial, petitioner testified that she conducted a private
medical practice at 1288 Victory Boulevard. The property at that
location was included as a rental property on petitioners'
Schedule E. On their return, petitioners claimed no Schedule C
deductions related to petitioner's medical practice. At trial,
however, petitioners sought deductions for certain expenses
related to petitioner's medical practice.
Taxpayers are required to maintain records that are
sufficient to enable the Commissioner to determine their correct
tax liability. See Meneguzzo v. Commissioner, 43 T.C. 824, 831-
832 (1965); sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Additionally, a taxpayer who claims a deduction bears the burden
of substantiating the amount and purpose of the item claimed.
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