Ronna Joan Robertson - Page 5




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          license.  Petitioner paid $403.95 in 1994 for expenses relating             
          to a Delaware corporation of which she was a shareholder.                   
          Finally, petitioner paid interest of $481.65 and $118.19 in 1993            
          and 1994, respectively, on a personal loan for an automobile.               
                                       OPINION                                        
               We must decide whether petitioner (1) is entitled to any               
          Schedule A itemized deductions for the 1993 and 1994 taxable                
          years; (2) is liable for additional tax under section 72; and (3)           
          is liable for any additions to tax under section 6651(a) or                 
          6654(a).                                                                    
          I.  Schedule A Itemized Deductions                                          
               Deductions are a matter of legislative grace, and petitioner           
          bears the burden of proving that she is entitled to the                     
          deductions she is claiming.  See Rule 142(a); INDOPCO, Inc. v.              
          Commissioner, 503 U.S. 79 (1992); New Colonial Ice Co. v.                   
          Helvering, 292 U.S. 435 (1934).  Taxpayers are required to                  
          maintain records that are sufficient to enable the Commissioner             
          to determine their correct tax liability.  See sec. 6001;                   
          Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965); sec.                
          1.6001-1(a), Income Tax Regs.  Moreover, a taxpayer who is                  
          claiming a deduction bears the burden of substantiating the                 
          amount and purpose of the item claimed.  See Hradesky v.                    
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax Regs.                     






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