James W. Harris and Dorthy R. Harris - Page 8

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          or end of 1992.  Respondent's analysis also was based on the                
          assumption that petitioners spent $63,297 in cash on the                    
          expenses, other than depreciation, which they claimed on their              
          return for Harris Enterprises.                                              
                                       OPINION                                        
               We decide the subject issues seriatim.  We bear in mind that           
          petitioners bear the burden of proof, Rule 142(a); Welch v.                 
          Helvering, 290 U.S. 111, 115 (1933), and that Congress has                  
          required taxpayers to keep sufficient records to substantiate any           
          deduction that is otherwise allowed by the Code, sec. 6001; see             
          also New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).           
          We also bear in mind that deductions are strictly a matter of               
          legislative grace, and that petitioners must prove their                    
          entitlement to the disputed deductions.  Rule 142(a); INDOPCO,              
          Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Rockwell v.                   
          Commissioner, 512 F.2d 882, 886 (9th Cir. 1975), affg. T.C. Memo.           
          1972-133; see also New Colonial Ice Co. v. Helvering, supra at              
          440 ("a taxpayer seeking a deduction must be able to point to an            
          applicable statute and show that * * * [the taxpayer] comes                 
          within its terms").  Petitioners rely mainly on the testimony of            
          Mr. Harris to attempt to meet their burden of proof.                        
          1.  Taxable Interest Income                                                 
               Respondent determined that petitioners failed to include in            
          their gross income $11,801 of interest income received by NBA on            






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