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1995 and 1996 alleged by petitioners or the estimated tax
payments shown on their returns. A portion of the $6,619 tax
liability shown on the return for 1995 was satisfied by an
overpayment credit from 1994 of $5,601.66. Petitioners had
previously made a $14,808 payment by check on January 16, 1996,
and designated that it be applied to tax years 1993 and 1994.
Taxpayers are required to substantiate the deductions and
credits that they claim on their returns by maintaining records
necessary to establish both the amount and their entitlement to
such items. Sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824,
831-832 (1965); sec. 1.6001-1(a), Income Tax Regs.; see Rule
142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992);
Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976); see also sec. 7491(a)(2)(A) and
(B).4
The parties stipulated copies of two letters written by
petitioner and addressed to the IRS office in Boston,
Massachusetts. In the letter dated June 16, 1997, petitioner
acknowledged receipt of tax change notices for 1995 and 1996 and
a request for payment of 1995 tax, penalty, and interest.
4Because petitioners have not met the requirements of sec.
7491(a)(2), they retain the burden of proof on this issue.
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