Curtis G. and Edna L. Lockett - Page 7

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          paid or incurred during the taxable year in carrying on any trade           
          or business.  To be entitled to a deduction under section 162(a),           
          a taxpayer is required to substantiate the deduction through the            
          maintenance of books and records.  Section 6001 requires                    
          generally that a taxpayer liable for any tax shall maintain such            
          records, render such statements, make such returns, and comply              
          with such regulations as the Secretary may from time to time                
          prescribe.  The meager records petitioner presented to                      
          substantiate the expenses at issue do not satisfy the                       
          recordkeeping requirements of section 6001 and do not prove that            
          the expenses claimed were paid or incurred.  The Court holds that           
          petitioners have not sustained their burden of establishing their           
          entitlement to a deduction of their Schedule C expenses for 1991            
          and 1992.  Respondent, therefore, is sustained on this issue.               
               The second issue relates to the year 1991 and Schedule A,              
          Itemized Deductions, in the amount of $5,606.56 claimed by                  
          petitioners that were also disallowed by respondent for lack of             
          substantiation.  As noted above, petitioners claimed a deduction            
          of $360 for uniform rental and $5,435 for leftover equipment                
          expenses, subject to the limitation provisions of section 67(a).            
               The $5,435 represented payments petitioner claims he made              
          during 1991 on equipment that had been used in his construction             
          activity.  No documentary evidence was presented to substantiate            
          either the $5,435 for equipment payments or the $360 uniform                

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