Octavio and Felicitas Olvera - Page 7

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          support them.  Thus, we cannot infer from the evidence how much             
          of the funds actually was used to support petitioner's mother and           
          sister as opposed to Mrs. Olvera and petitioners' daughters.                
               Furthermore, petitioner testified that his sister, who may             
          have worked, received money from another source.  He also                   
          acknowledged that his nine siblings helped provide support at               
          times, although he stated that his parents did not receive any              
          governmental support or insurance.  Thus, petitioners have failed           
          to establish the total amount of support provided for                       
          petitioner's mother and sister from all sources, a prerequisite             
          to finding that petitioners provided one-half of either                     
          individual's support.  See Blanco v. Commissioner, 56 T.C. 512,             
          514 (1971).   Respondent is sustained on this issue.                        
          Schedule C Deductions                                                       
               Petitioners contend that they are entitled to Schedule C               
          deductions in the amounts disallowed by respondent.  Section 162            
          allows a deduction for all ordinary and necessary expenses paid             
          or incurred in carrying on a trade or business.  Generally, when            
          evidence shows that the taxpayers paid a deductible expense but             
          the exact amount cannot be determined, the Court may approximate            
          the amount.  Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).             
          An exception to the Cohan rule is section 274(d), which requires            
          strict substantiation of certain expenses, including those paid             
          or incurred with respect to certain listed property.  Sec.                  






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