Anand K. Verma - Page 10




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          section, an expense must be directly connected with, or                     
          proximately result from, a trade or business of the taxpayer.               
          See Kornhauser v. United States, 276 U.S. 145, 153 (1928);                  
          O’Malley v. Commissioner, 91 T.C. 352, 361 (1988).  Personal                
          expenses are generally not allowed as deductions.  See sec.                 
          262(a).  Deductions are a matter of legislative grace, and                  
          taxpayers must comply with the specific requirements for any                
          deduction claimed.  See INDOPCO, Inc. v. Commissioner, 503 U.S.             
          79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,             
          440 (1934).                                                                 
               A taxpayer is required to maintain records sufficient to               
          establish the amount of his income and deductions.  See sec.                
          6001; sec. 1.6001-1(a), (e), Income Tax Regs.  A taxpayer must              
          substantiate his deductions by maintaining sufficient books and             
          records to be entitled to a deduction under section 162(a).                 
               When a taxpayer establishes that he has incurred a                     
          deductible expense but is unable to substantiate the exact                  
          amount, we are, in some circumstances, permitted to estimate the            
          deductible amount.  See Cohan v. Commissioner, 39 F.2d 540, 543-            
          544 (2d Cir. 1930).  We can estimate the amount of the deductible           
          expense only when the taxpayer provides evidence sufficient to              
          establish a rational basis upon which the estimate can be made.             
          See Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).                       








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