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Petitioner obtained his jobs through contractors he had met over
the years and with whom he maintained contact. Periodically they
called him when jobs became available.
It was not practical for petitioner to have a checking
account in each of the States in which he worked. Even if he had
such accounts, the casual labor hired by petitioner usually
insisted on payment in cash. Petitioner kept no record of the
persons he employed during the year. But he deducted on Schedule
C wage expenses of $6,025 of which respondent disallowed $5,550.
Although petitioner did not keep contemporaneous business
records, he did attempt to reconstruct his truck mileage.
Entitled "Approx Work Mileage 1996", the reconstructed record
consists of handwritten sheets with dates, locations, and trip
distances. Petitioner deducted $9,244 as car and truck expenses
on his Schedule C. His reconstructed mileage total for the year
is 29,390 miles.
Petitioner reported a net profit from business of $256 on
his Schedule C for 1996. The tax return reports total taxable
income for the year of $0.
OPINION
Substantiation of Schedule C Expenses
Petitioner must show that the amounts claimed are deductible
business expenses. Rule 142(a); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934); Hradesky v. Commissioner, 65
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