- 19 - business purpose. See Moylan v. Commissioner, T.C. Memo. 1968-15 (expenses of golf outings disallowed where taxpayer did not show direct relationship between expense and conduct of business); sec. 1.274-5T(b)(3), Temporary Income Tax Regs. We sustain respondent’s adjustment to petitioner’s meals and entertainment expense deduction as modified. Wage Expense On his 1994 Schedule C, petitioner claimed a deduction for wages in the amount of $2,340. The items allegedly included in calculating the deduction were listed on an exhibit entitled “1994 Wage Expenses”. Petitioner contends that he paid various people amounts from $30 to $250 for clerical and research work and for computer training. Petitioner did not maintain any documentation regarding the alleged wage payments. Although he claimed that he made the payments in cash, he did not obtain any receipts for the payments. The record is devoid of any credible evidence substantiating the alleged wage payments. As a businessperson, petitioner surely knew that he was required to substantiate his business deductions. Petitioner failed to offer any evidence other than his own testimony to prove that he actually made the wage payments. We are not required to accept a taxpayer’s self- serving and uncorroborated testimony. See Wood v. Commissioner,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011