- 10 - their transfer to Appeals request indicates that petitioners feel that respondent's position on the adjustment was not reasonable in fact based upon their statements to respondent. As to that argument, respondent asserts that it was incumbent upon petitioners to substantiate their entitlement to the items claimed. It is reasonable, according to respondent, not to concede an adjustment until he has received and verified adequate substantiation for the items in question. He therefore concludes that as to the stated adjustment, his position was reasonable when taken and appropriately conceded when substantiation was provided to Appeals. Taxpayers are required to maintain books and records in accordance with rules and regulations prescribed by the Secretary of the Treasury. See sec. 6001. Generally, taxpayers must keep records sufficient to establish gross income, deductions, or other matters required to be shown on the return. See sec. 1.6001-1(a), Income Tax Regs. Petitioners' request for transfer to Appeals argues that the Code does not require an employer to indicate that an employee is a statutory employee and that petitioners sent the Commissioner a letter describing petitioner's duties. Regardless of what responsibility petitioner's employers may have had, it was petitioner's responsibility to verify her entitlement to report income and deductions on Schedule C. The Forms W-2 attached toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011