Greta Ann Clifton - Page 10

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               A taxpayer may deduct ordinary and necessary expenses paid             
          or incurred during the taxable year in carrying on a trade or               
          business.  Sec. 162(a).  Deductions are a matter of legislative             
          grace, and the taxpayer bears the burden of proving that she is             
          entitled to claimed deductions.  Rule 142(a); New Colonial Ice              
          Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering,             
          supra at 115.  This includes the burden of substantiating the               
          amount and purpose of the item claimed.  Sec. 6001; Hradesky v.             
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax Regs.  However,           
          if certain claimed deductions are not adequately substantiated,             
          we are permitted to estimate them, provided we are convinced from           
          the record that the taxpayer has incurred such expenses and we              
          have a basis upon which to make an estimate.  Cohan v. Commis-              
          sioner, 39 F.2d 540 (2d Cir. 1930); Vanicek v. Commissioner, 85             
          T.C. 731, 743 (1985).                                                       
               A.  Bank Service Charges                                               
               Respondent determined that petitioner was not entitled to a            
          deduction for bank service charges.  Petitioner asserts that such           
          a deduction is allowable.                                                   
               During 1985, petitioner had three bank accounts in her name:           
          A Norbank account, a Lafayette County Bank (Lafayette Bank)                 
          account, and a Blue Springs Bank account.  Petitioner's account             
          with Norbank was separate from Orad's Norbank account.                      
          Petitioner had $105 in bank service charges arising from her                

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