Tina & Sheafen Kuo - Page 4




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          and rental expenses of $9,330 on Schedule E, Supplemental Income            
          and Loss.  Respondent disallowed $13,529 of the business expenses           
          and $7,292 of the rental expenses.1                                         
               Section 162(a) allows a deduction for the ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  Section 212(2) allows a                   
          deduction for the ordinary and necessary expenses paid during the           
          taxable year for the management, conservation, or maintenance of            
          property held for the production of income.  Section 262 provides           
          that no deduction is allowed for personal, living, or family                
          expenses.                                                                   
               Taxpayers generally must keep sufficient records to                    
          establish the amounts of claimed deductions.  See sec. 6001;                
          Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).  With               
          certain exceptions, in the event that a taxpayer establishes that           
          a deductible expense has been paid but is unable to substantiate            
          the precise amount, we may estimate the amount of the deductible            
          expense, bearing heavily against the taxpayer whose inexactitude            
          in substantiating the amounts of the expenses is of his own                 
          making.  See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.           
          1930).  We cannot estimate deductible expenses, however, unless             
          the taxpayer presents evidence sufficient to provide some basis             



          1Petitioners concede several individual business and rental                 
          expense deductions which we need not list in detail.                        





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