- 8 - Dugan v. Commissioner, supra (“Given that petitioner has failed to demonstrate the business purpose for the computer expense in accordance with section 274(d), the [section 179] deduction is disallowed.”). C. Office Expenses Petitioners claim a deduction for office expenses in the amount of $8,762. Section 162(a) allows as a deduction “all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business”. Office expenses of the type claimed by petitioner, e.g., postage, if paid or incurred during the taxable year in carrying on any trade or business, can qualify as deductible section 162(a) expenses. See sec. 1.162- 1(a), Income Tax Regs. The adequate-records-or-sufficient- corroborating-evidence standard of section 274(d) is not specifically applicable to such expenses. Nevertheless, a taxpayer is required by section 6001 to keep records and to substantiate the amounts giving rise to claimed deductions, and, if he does not, respondent cannot be considered arbitrary or unreasonable in denying the deductions. Roberts v. Commissioner, 62 T.C. 834, 836-837 (1974); Cook v. Commissioner, T.C. Memo. 1991-590 (citing Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976)); see sec. 1.6001- 1(a), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011