- 4 - table in this area which petitioner does not clear off for eating his meals. In his apartment, petitioner has three televisions, which he watches for recreation. In the notice of deficiency respondent made the following adjustments to Schedule C deductions by petitioner: 1996 Claimed Allowed Disallowed Car and truck $4,900 $1,225 $3,675 Interest 250 0 250 Travel 2,864 1,682 1,182 Utilities 120 26 94 Exhibits 575 550 25 General 1,949 683 1,266 Association 225 227 (2) fees Business use of 4,130 826 3,304 home Total $15,013 $5,219 $9,794 All numbers are rounded up to the nearest dollar. Respondent disallowed deductions in the amounts shown above because petitioner failed to show that each claimed deduction was an ordinary and necessary business expense, or, in the alternative, because petitioner failed to substantiate the claimed deduction. Discussion Deductions are a matter of legislative grace, and the taxpayer bears the burden of proving the entitlement to any deduction claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). A taxpayer is required to maintain records sufficient toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011