Inez T. Morin - Page 4




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          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.2d              





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