- 3 - On Schedule A filed with his 1993 Federal income tax return, petitioner claimed the following as unreimbursed employee business expenses: Expense Amount Vehicle $6,351 Parking 780 Travel 5,892 Business 6,986 Meals and entertainment1 5,594 Total 25,603 1 After the 20 percent reduction. See sec. 274(n). Respondent disallowed the claimed expenses for failure to substantiate. Petitioner alleges that his records were destroyed in November 1996 due to a rainstorm which flooded his apartment. Petitioner recently found copies of the calendar in storage. Deductions are a matter of legislative grace. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). A taxpayer must substantiate any deductions claimed and bear the burden of substantiation. See Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). Taxpayers are required to maintain adequate records sufficient to establish the amounts of the deductions. See sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965). Section 162(a) allows a taxpayer to deduct all ordinary and necessary business expenses paid or incurred during the taxablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011