- 18 - petitioners’ Schedule C gross receipts for each of the years at issue. Claimed Schedule C Deductions Respondent disallowed petitioners’ claimed Schedule C car and truck expenses for 1993, 1994, and 1995 in the amounts of $11,550, $9,352, and $16,875, respectively.9 Deductions are strictly a matter of legislative grace, and petitioners bear the burden of proving that they are entitled to any deductions claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Section 162(a) allows a deduction for ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. Section 274(d)(4) operates to disallow any deduction otherwise allowable under, inter alia, section 162(a) with respect to, inter alia, any “listed property”, unless the taxpayer satisfies the substantiation requirements of that section.10 “Listed property” is defined in section 280F(d)(4) to 9Respondent did not disallow the remaining claimed Schedule C car and truck expenses for 1993, 1994, and 1995 in the amounts of $5,250, $5,438, and $5,625, respectively. 10Sec. 274(d) provides in pertinent part: SEC. 274. DISALLOWANCE OF CERTAIN ENTERTAINMENT, ETC., EXPENSES. (d) Substantiation Required.–-No deduction or credit shall be allowed-- (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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