George H. Richards - Page 15

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          amount of his deductions.  Sec. 6001; sec. 1.6001-1(a), Income              
          Tax Regs.  If a taxpayer is unable to fully substantiate the                
          expenses incurred in his trade or business but there is evidence            
          that deductible expenses were incurred, the Court may                       
          nevertheless allow a deduction based upon an approximation of               
          expenses.  Ellis Banking Corp. v. Commissioner, 688 F.2d 1376               
          (11th Cir. 1982), affg. in part and remanding in part T.C. Memo.            
          1981-123; Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir. 1930);           
          Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).                       
               Respondent does not dispute and we conclude that petitioner            
          was in the trade or business of performing architectural CAD                
          drafting services in 1997.  Respondent argues that petitioner               
          failed to substantiate the expenses for which he claimed                    
          deductions on his Schedule C.  We shall discuss each claimed                
          expense below.                                                              
                    A.  Car and Truck Expenses                                        
               Petitioner claimed a deduction of $186 on his Schedule C for           
          car and truck expenses.  It is not clear from his Schedule C or             
          the attached Form 4562, Depreciation and Amortization, whether              
          the claimed amount represents depreciation for his Nissan Altima            
          automobile, a standard mileage allowance, or actual expenses such           
          as gasoline and tolls.                                                      
               To deduct expenses, such as depreciation, with respect to              
          “listed property” under section 280F(d)(4)(i), which includes an            

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