Chrys L. Udoh - Page 6




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          of petitioner's claimed expenses, and he also disallowed $1,002             
          of cost of goods sold for 1995 due to lack of substantiation.               
          Discussion                                                                  
          1.   Schedule C Expenses                                                    
               Deductions are a matter of legislative grace, and a taxpayer           
          seeking a deduction must establish his entitlement to the                   
          deduction claimed.  See New Colonial Ice Co. v. Helvering, 292              
          U.S. 435, 440 (1934).                                                       
               Section 162(a) generally provides that there shall be                  
          allowed as a deduction all the ordinary and necessary expenses              
          paid or incurred during the taxable year in carrying on a trade             
          or business.  To be entitled to a deduction under section 162(a),           
          a taxpayer is required to substantiate the deduction through the            
          maintenance of books and records.  Section 6001 requires                    
          generally that a taxpayer liable for any tax shall maintain such            
          records, render such statements, make such returns, and comply              
          with such regulations as the Secretary may from time to time                
          prescribe.                                                                  
               While petitioner testified that he incurred certain                    
          expenses, he concluded that he incurred a loss in his business in           
          the amount of $355.  The record shows the transaction from which            
          the loss originated took place in 1996.  The loss is not properly           
          deductible in 1994 or 1995.                                                 







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