- 4 -
Included among the deductions claimed by petitioner on his
Schedules C for 1997 and 1998 were the following:
1997 1998
Car and truck expenses $8,820 $9,100
Employee benefit programs 2,800 2,400
Insurance 1,296 ---
The deductions claimed by petitioner for “Car and truck
expenses” represented the cost of commuting between petitioner’s
home and workplace. The deductions claimed by petitioner for
“Employee benefit programs” represented the cost of certain
family vacations. The deduction claimed by petitioner for
“Insurance” represented monthly premiums paid for a policy of
life insurance purchased by petitioner to provide income security
for his family in the event of his death.
C. Notice of Deficiency
In the notice of deficiency, respondent disallowed the
Schedule C deductions claimed by petitioner for “Car and truck
expenses” and “Employee benefit programs” in 1997 and 1998 and
for “Insurance” in 1997. Although respondent agrees that
petitioners substantiated these deductions as to payment,
respondent contends that the expenditures in question are not
deductible as a matter of law.
Discussion
It has long been held that deductions are a matter of
legislative grace and “only as there is clear provision therefor
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011