- 3 - deducted $59,323 in total expenses from $82,528 of gross receipts for a net profit of $23,205. On her first Schedule C, petitioner described MBS as an accounting, bookkeeping, and income tax business. On her second Schedule C for “A Joyful Wedding”, which was described as minister services, petitioner deducted $12,871 of total expenses from $13,600 of gross receipts for a net profit of $729. Respondent disallowed $59,323 of deductions for the first Schedule C and $12,871 for the second Schedule C because petitioner did not establish that the business expenses shown on her return were paid or incurred during the taxable year and that the expenses were ordinary and necessary to her businesses. At trial, respondent conceded that petitioner was engaged in two businesses. Respondent in the notice of deficiency determined that the $9,240 amount reported as other income for notary public services was gross receipts of MBS and was subject to self- employment tax. The notice of deficiency attributed another $3,600 of income to gross receipts of MBS, but respondent conceded this amount at trial. 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.2dPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011