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incurred in connection with the income. Consequently, we proceed
as though petitioner conceded the correctness of the adjustments
contained in the notice of deficiency and consider his claim for
additional deductions.
According to petitioner, he “had a huge amount of business
expenses * * * because * * * [he] was a commissioned
salesperson”. Petitioner further testified that these expenses
would offset the income attributed to him in the notice of
deficiency.
Petitioner was engaged in one or more trades or businesses
during each of the years in issue. In general, a taxpayer is
entitled to a deduction for all ordinary and necessary expenses
paid or incurred in carrying on the taxpayer’s trade or business.
Sec. 162(a). Entitlement to a deduction presupposes that the
taxpayer can substantiate by adequate books and records the
amount of the deduction claimed. Sec. 6001; sec. 1.6001-1(a),
Income Tax Regs.
Petitioner’s business records were not made available to the
Court. Petitioner claims that his records for the years 1990
through 1996 were confiscated by a storage company because he
failed to pay the required storage fees; he claims his records
for 1997 and 1998 are in the possession of an accountant who will
not return the records until petitioner pays the accountant for
services rendered.
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Last modified: May 25, 2011