- 9 - 79, 84 (1992). Petitioner must show that respondent’s determination is in error. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Section 162(a) permits a deduction for the ordinary and necessary expenses paid or incurred during the taxable year in carrying on a trade or business. Expenses that are personal in nature are generally not allowed as deductions. Sec. 262(a). A taxpayer is required to maintain records sufficient to establish the amount of his income and deductions. Sec. 6001; Higbee v. Commissioner, 116 T.C. 438, 440 (2001); sec. 1.6001-1(a),(e), Income Tax Regs. Petitioner contends that he is entitled to the full amount of deductions claimed. Petitioner, however, did not show entitlement to business deductions in excess of the amounts allowed by respondent. At trial and on brief, petitioner generally attempted to explain the deductions claimed for 1990 and 1991. Petitioner’s explanations were insufficient to either show error in respondent’s determination or substantiate entitlement to more deductions in excess of the amounts already allowed by respondent. We must note that testimony during the trial revealed that respondent’s agent had given petitioner the “benefit of the doubt” and that some deductions were allowed by respondent without thorough substantiation or based on a pattern ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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