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would record the time and place of the recording session in Mrs.
Popov’s calendar. Mrs. Popov worked for 24 contractors during
1993 and recorded at 38 locations. The recording sessions were
scheduled in either 3- or 6-hour blocks of time, and Mrs. Popov
was paid by the contractor. Mrs. Popov received a total of 26
Forms W-2 for 1993.
In the notice of deficiency, respondent disallowed the
Schedule A expenses, stating that petitioners have not
established that the expenses were paid or incurred during the
taxable year, or if the expenses were incurred, petitioners have
not shown that these are deductible expenses. At trial,
respondent further contended that the car and truck and the meals
and entertainment expenses lacked substantiation.
Section 162(a) permits the deduction of "ordinary and
necessary" expenses paid or incurred during the taxable year in
carrying on any trade or business. Taxpayers must keep
sufficient records to establish deduction amounts. Sec. 6001;
Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).
Home Office and Electricity
Neither the various contractors, the Los Angeles Chamber
Orchestra, nor the Long Beach Symphony provided a place for Mrs.
Popov to practice, although it was expected that the musicians
would practice daily. For the recording sessions, Mrs. Popov
would not receive the sheet music in advance in order to
rehearse. Once the musicians arrived at the studio, they would
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