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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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