- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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