Jasbinder Singh - Page 3




                                         -3-                                          
                                       OPINION                                        
               On the basis of documentation petitioner provided,                     
          respondent conceded that petitioner is entitled to many of the              
          disallowed Schedule C expenses.  Petitioner contends that he is             
          entitled to additional expense deductions for fuel and expenses             
          related to his car, which he used to travel from his home to his            
          workplace, the yard where his truck was parked.                             
               Section 162(a) allows a taxpayer to deduct "all the ordinary           
          and necessary expenses paid or incurred * * * in carrying on any            
          trade or business".  Deductions are a matter of legislative                 
          grace, and the taxpayer bears the burden of proving that he is              
          entitled to any deductions claimed.  Rule 142(a); INDOPCO, Inc.             
          v. Commissioner, 503 U.S. 79, 84 (1992).  Taxpayers bear the                
          burden of substantiating 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 maintain adequate           
          records sufficient to enable the Commissioner to determine their            
          correct tax liability.  Sec. 6001; Meneguzzo v. Commissioner, 43            
          T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income Tax Regs.                
               At trial, petitioner did not provide the Court any evidence            
          showing his entitlement to the Schedule C expense deductions that           
          remain at issue.  Furthermore, petitioner may not deduct the                
          expenses incurred in traveling between his home and his                     
          workplace.  It is well established that expenses incurred by a              






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