- 14 - with the Oak Village Middle School. Further, petitioner only selected the middle school option when asked to select the appropriate options that applied to the applicant. Petitioner unequivocally completed both applications as an educator, making no mention whatsoever of PK Production. Petitioner testified that he had a choice of associating himself with the school or PK Production when completing the applications, yet petitioner chose to affiliate himself with the school on both occasions. It appears to the Court that from the evidence presented that petitioner attended both San Antonio, Texas, conventions primarily in his capacity as an assistant band director. The record is clear that petitioner has failed to establish that the expenses associated with the San Antonio, Texas, conventions claimed on Schedule C were ordinary and necessary expenses directly related to PK Production. See sec. 162(a); sec. 1.162- 1(a), Income Tax Regs. Petitioner presented absolutely no evidence, either documentary or testimonial, to substantiate the additional $65.06 of expenses claimed as music educator and professional convention expenses. Petitioner is not entitled to a deduction for business expenses that are completely unsubstantiated. Ronnen v. Commissioner, supra. Therefore, petitioner is not entitled to a Schedule CPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011