John Norman Favero and Patricia Carolyn Favero - Page 7




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          petitioners have failed to provide any evidence establishing that           
          Mrs. Favero’s claimed expenses were incurred for business                   
          purposes.  Section 162(a) allows a deduction for all the ordinary           
          and necessary expenses paid or incurred during the taxable year             
          in carrying on a trade or business.  Section 262(a), however,               
          provides that no deduction is allowed for personal, living, or              
          family expenses.  Taxpayers are required to maintain records                
          sufficient to substantiate their claimed deductions.  Sec. 6001;            
          sec. 1.6001-1(a), Income Tax Regs.  Mrs. Favero’s testimony was             
          vague, and the copies of checks and receipts submitted as                   
          evidence of her business expenses provide no basis to determine             
          the nature of the expenditures.  Petitioners, therefore, are not            
          entitled to the Schedule C deductions disallowed by respondent.             
               Petitioners likewise have failed to establish they are                 
          entitled to Schedule E expenses beyond those allowed by                     
          respondent.  Although section 212 allows a deduction for ordinary           
          and necessary expenses paid or incurred during the taxable year             
          for the management, conservation, or maintenance of property held           
          for the production of income, nothing in the record establishes             
          that the expenses disallowed by respondent were incurred.  At               
          trial, Mrs. Favero indicated that some of the copies of checks              
          and receipts she submitted into evidence related to the                     
          automobile expenses claimed on petitioners’ Schedule E.  As with            
          the Schedule C expenses, the copies of checks and receipts                  






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