Larry D. & Marie A. Land - Page 5




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               Petitioner claimed $16,000 of deductions for prototype                 
          manufacturing expense on New Tech's Schedule C.  The money was              
          for the production of country and western CDs which petitioner              
          planned to give away.  Petitioner thought that if he gave away              
          the CDs, people would invest in that endeavor.  Respondent                  
          contends that this $16,000 prototype expense was an expense of              
          the Nashville North, LLC, partnership, because the partnership              
          was the entity promoting Greg Shires, the singer on the CDs.                
          Petitioner agreed with this characterization at trial.                      
          Accordingly, the expense belonged to the partnership.  We sustain           
          respondent's determination as to this issue.                                
               Respondent disallowed $3,276 of vehicle expense deducted on            
          petitioners' New Tech Schedule C.  Deductions are strictly a                
          matter of legislative grace.  INDOPCO, Inc. v. Commissioner, 503            
          U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S.             
          435, 440 (1934).  Taxpayers must substantiate claimed deductions.           
          Hradesky v. Commissioner, 65 T.C. 87, 89 (1975), affd. per curiam           
          540 F.2d 821 (5th Cir. 1976).  Moreover, taxpayers must keep                
          sufficient records to establish the amounts of the deductions.              
          Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965); sec. 1.6001-            
          1(a), Income Tax Regs.                                                      
               Section 274(d) imposes stringent substantiation requirements           
          for the deduction of travel expenses and automobile expenses.               
          Taxpayers must substantiate by adequate records certain items in            






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