William F. Middleton - Page 9




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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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