Robert W. and Jennifer J. Fritz - Page 5

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          otherwise.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115              
               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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