- 5 -
otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933).
Taxpayers must substantiate the amount of any deductions
claimed. Hradesky v. Commissioner, 65 T.C. 87, 89 (1975), affd.
per curiam 540 F.2d 821 (5th Cir. 1976). In addition, they must
prove that these expenses are ordinary and necessary business
expenses. Sec. 162(a). Expenditures must be "directly connected
with or pertaining to the taxpayer's trade or business". Sec.
1.162-1(a), Income Tax Regs. Our review of the record indicates
that petitioners have failed to substantiate a deduction in an
amount in excess of that already allowed by respondent.
At trial, petitioners introduced the following evidence of
their car and truck expenses for 1987. First, petitioners
offered numerous charge slips, many of which are from Carter's
Amoco, a gasoline station in Washington, Pennsylvania. These
charge slips total $11,605.15. Petitioners have failed to prove,
however, that many of these charges were ever paid. Some of the
charge slips bear the notation "paid" or "cash". We find that
these charges, which total $4,000.62, have been paid by
petitioners. Petitioners have not established that they are
entitled to claim a deduction for the remaining $7,604.53. See
sec. 1.446-1(c)(1)(i), Income Tax Regs.
In addition, petitioners presented carbon copies of two
checks totaling $2,453.43. These checks were drawn on Dollar
Bank in Pittsburgh, Pennsylvania, and made payable to Carter's
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