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promulgated under section 162 clarify that only those ordinary
and necessary business expenses "directly connected with or
pertaining to the taxpayer's trade or business" may be deducted.
Sec. 1.162-1(a), Income Tax Regs. In addition, under section
262(a) no portion of the expenditures attributable to personal,
living, or family expenses may be deducted, except as otherwise
expressly provided in the Code.
Petitioner testified that he paid $1,188 during 1990 for the
use of a laser printer. He explained that he rented the printer
from January through April 1990 because he could not afford to
purchase the equipment outright. In support of his deduction, at
trial petitioner presented two canceled checks written in January
and March, each in the amount of $297, which respondent agreed
would be allowable. Petitioner was unable to produce any
documentation to support the remainder of his deduction.
In light of his profession as an income tax return preparer,
petitioner should have been well aware of the requirement of a
taxpayer to maintain adequate records to substantiate his income
and deductions. Petitioner claims that he is unable to provide
documentation because he was locked out of his office in June
1991 for failure to pay his rent, and all of his records were in
the office. Petitioner presented no evidence to support his
claim of eviction, nor did he explain why he did not request
supporting statements from his bank to establish that the monies
had in fact been paid. Moreover, we found petitioner's testimony
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