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is the requirement that petitioner substantiate his claimed
deductions. Hradesky v. Commissioner, 65 T.C. 87 (1975), affd.
per curiam 540 F.2d 821 (5th Cir. 1976).
Section 6001 imposes upon every person liable for any tax a
duty to maintain records that are sufficient to enable the
Commissioner to determine the taxpayer's correct tax liability.
Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965); sec. 1.6001-
1(a), Income Tax Regs.
Section 162(a) provides for the deduction of all ordinary
and necessary expenses paid or incurred during the taxable year
in carrying on a trade or business. Only ordinary and necessary
business expenditures directly connected with or pertaining to
the taxpayer's trade or business are deductible from gross
income. Sec. 1.162-1(a), Income Tax Regs. Whether or not a
payment constitutes an ordinary and necessary business expense
is, in most instances, a question of fact.
After a review of the record, we conclude that petitioner
failed to meet his burden of proof. Petitioner failed to
produced any documentary or corroborative evidence to
substantiate that the claimed expenses were ordinary and
necessary, and that they were in fact paid or incurred in the
course of his law practice.
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