- 3 - Forestville Oakland Property Property Claimed Allowed Claimed Allowed Cleaning and maintenance $4,073 $405 $2,186 $186 Repairs 4,153 55 Supplies 1,741 1,488 Petitioner also claimed miscellaneous itemized deductions for travel and transportation expenses of $6,373. Respondent determined that petitioner was entitled to deductions of only $4,946.2 A taxpayer generally must keep records sufficient to establish the amounts of the items reported on her Federal income tax return. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. However, in the event that a taxpayer establishes that a deductible expense has been paid but that she is unable to substantiate the precise amount, we generally may estimate the amount of the deductible expense bearing heavily against the taxpayer whose inexactitude in substantiating the amount of the expense is of her own making. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). We cannot estimate a deductible expense, however, unless the taxpayer presents evidence 1(...continued) Forestville property. 2Respondent’s adjustment to the miscellaneous itemized deductions pursuant to the sec. 67(a) limitation is computational and will be resolved by the Court’s holding on the issue in this case.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011