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devoid of any evidence that any of these expenses satisfy the
heightened substantiation requirements of section 274(d).
We hold for respondent on this issue.
C. Rent Expenses
Respondent contends that, under section 162(a), petitioner
is not entitled to the disputed rent business expenses deduction
because petitioner has failed to substantiate that the expenses
(1) were incurred and (2) were ordinary and necessary expenses of
petitioner’s trade or business.
Petitioner maintains that the requirements of section 162(a)
are satisfied.
We agree with respondent.
A taxpayer seeking a deduction has the burden of overcoming
the presumption of correctness that attaches to the
Commissioner’s factual determinations in the notice of
deficiency. See Rule 142(a); New Colonial Ice Co. v. Helvering,
supra; Welch v. Helvering, supra.
Section 162(a) allows a deduction for “all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business”. See, e.g., Lucas v.
Commissioner, supra. Under section 6001 and section 1.6001-1(a)
and (e), Income Tax Regs., a taxpayer must keep such permanent
books of account or records as are sufficient to establish the
amount of gross income, deductions, credit, or other matters
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