-13- previously claimed Schedule A unreimbursed employee business expenses as Schedule C business expenses associated with petitioner’s services as an “independent contractor”. Petitioners also increased the amount of the deduction from $51,363.96 to $57,348. The expenses claimed on Schedule C were: Advertising $513 Bad debt 10,000 Car operating expenses 6,201 Depreciation (car) 2,850 Depreciation (house) 10,300 Employee benefits (life 1,424 insurance) Interest (car) 1,660 Office expense 4,046 Supplies 9,023 Travel 7,465 Meals/entertainment 4,832 (less 20 percent of meals and entertainment) (966) Total $57,3487 Discussion Deductions are a matter of legislative grace. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers bear the burden of establishing that they are entitled to the claimed deductions. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 114 (1933). 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. 7 The parties stipulated that petitioners are not entitled to the $10,000 bad debt deduction.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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