- 7 - 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 receiptsPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011