- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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