- 9 - petitioner refused to provide records, invoking Fifth Amendment). For the foregoing reasons, we reject petitioner's assertions. Petitioner also contends that respondent, in the course of the examination, abridged petitioner's copyright interest in a 1993 article entitled, "The Audit of '91". Petitioner's copyright infringement claims have no foundation. Respondent is entitled to examine petitioner's literary works in order to establish whether there was a connection between petitioner's claimed business deductions and petitioner's business as a writer. Accordingly, we reject petitioner's arguments. 2. Schedule C Deductions We now turn to the question of whether petitioner may properly claim the deductions in question. As explained supra, petitioner bears the burden of proving entitlement to any claimed deductions. In this regard, taxpayers must keep sufficient records to establish the amount of deductions or other matters required to be shown on the taxpayer's return. Sec. 1.6001-1(a), Income Tax Regs. Section 162(a) generally allows a deduction for "ordinary and necessary" expenses incurred while carrying on a trade or business. Respondent does not appear to question that petitioner's writing activities constitute a "trade or business". Respondent, however, argues that petitioner has failed to prove that the deductions claimed are "ordinary and necessary" expensesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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