Perry H. Kay, Sr. - Page 11




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          entitled to a vehicle expense deduction of $1,866 for the year at           
          issue.                                                                      
               B.  Production and Management Fees                                     
               Petitioner claimed a business expense deduction for                    
          production and management fees in the amount of $999.20 on                  
          Schedule C for the year at issue.  At trial, petitioner presented           
          documentation substantiating $486.70 of the amount claimed.  We             
          are satisfied that the substantiated items are ordinary and                 
          necessary business expenses directly connected with petitioner’s            
          Schedule C business, as required under section 162(a) and the               
          regulations thereunder.                                                     
               Petitioner presented absolutely no evidence, either                    
          documentary or testimonial, to substantiate the additional                  
          $512.50 of expenses claimed.  Petitioner is not entitled to a               
          deduction for business expenses that are completely                         
          unsubstantiated.  Ronnen v. Commissioner, 90 T.C. 74, 102 (1988).           
               Therefore, petitioner is entitled to a Schedule C business             
          expense deduction only for production and management fees in the            
          amount of $486.70 for the year at issue.                                    
               C.  Music Educator and Professional Convention Expense                 
               Petitioner claimed a business expense deduction for music              
          educator and professional convention expenses in the amount of              
          $1,381.44 on Schedule C for the year at issue.  After                       
          respondent’s concession allowing a deduction of $1,047.49 for               






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