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to and from work, such expenses are considered nondeductible
personal living expenses. Sullivan v. Commissioner, 45 T.C. 217
(1965), affd. 368 F.2d 1007 (2d Cir. 1966); sec. 1.262-1(b)(5),
Income Tax Regs. The parking, car and truck, travel, meals,
entertainment, and membership fee expenses were not properly
substantiated under the cited legal standards. Petitioner,
therefore, is not entitled to deductions in excess of amounts
allowed by respondent.
Section 170 allows a deduction for charitable contributions
during the taxable year, if verified as provided in the
regulations. Sec. 170(a)(1). Ordinarily, charitable
contributions are deducted on Schedule A, pursuant to section
170. However, an individual may be entitled to claim a payment
to a charitable organization as a trade or business expense on
Schedule C, if no part of such payment is allowable under section
170. Sec. 1.162-15(a), Income Tax Regs. Generally, such a
payment may be claimed as a deduction on Schedule C to the extent
that it bears a direct relationship to the taxpayer’s trade or
business and is made with a reasonable expectation of a financial
return commensurate with the amount of the payment. Cf. sec.
1.162-15(b), Income Tax Regs.
Although petitioner did not substantiate his claimed
charitable contributions with written documentation, the Court is
satisfied that petitioner did make some payments qualifying as
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