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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 of
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