Debra L. Streck and Donald W. Streck - Page 12

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               Respondent's determinations are presumed correct, and                  
          petitioners bear the burden of proving otherwise.  Rule 142(a);             
          Welch v. Helvering, 290 U.S. 111, 115 (1933).  Deductions are a             
          matter of legislative grace, and taxpayers bear the burden of               
          proving that they are entitled to any deduction claimed.  New               
          Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).                    
          Taxpayers must substantiate the amount of any deductions claimed.           
          Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd. per               
          curiam 540 F.2d 821 (5th Cir. 1976).  Taxpayers are required to             
          keep sufficient records to enable the Commissioner to determine             
          their correct tax liability.  Sec. 6001.                                    
               Section 162 allows the deduction of ordinary and necessary             
          expenses incurred in carrying on any trade or business.  Section            
          212 allows the deduction of ordinary and necessary expenses for             
          the production or collection of income or for the maintenance of            
          property held for the production of income. Petitioners failed              
          to substantiate their entitlement to deductions in an amount in             
          excess of that already allowed by respondent.  They did not                 
          produce records of Double D Ranch, Inc., such as journals,                  

               13(...continued)                                                       
                                              1984       1985     1986                
          Total income reported by           $1,500       $0     $18,817              
          Double D Ranch, Inc.                                                        
          Less:                                                                       
          Total interest paid             (71,644)   (69,590)  (58,228)               
          Total real estate taxes paid     (7,107)    (5,493)   (5,840)               
          Total loss allowed             ($77,251)  ($75,083) ($45,251)               




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