Cathy M. and Randy L. Crosson - Page 6

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               A taxpayer is required to maintain sufficient records to               
          establish the amounts of income and deductions.  Sec. 6001;                 
          Higbee v. Commissioner, 116 T.C. 438, 440 (2001); sec. 1.6001-              
          1(a), Income Tax Regs.  Petitioners have failed to provide any              
          substantiation to respondent or to this Court in support of the             
          claimed deductions for the $12,374 in car and truck expenses,               
          $420 in legal and professional services, $116 in office expenses,           
          $299 in vehicle or equipment rent, $357 in supplies, $1,655 in              
          taxes and licenses, $312 in travel, $2,018 in meals and                     
          entertainment, $4,046 in utilities, and $1,625 in other expenses.           
              In addition to failing to substantiate the above expenses,             
          petitioners have failed to show that any were incurred in a trade           
          or business.  See Kornhauser v. United States, 276 U.S. 145, 153            
          (1928); O’Malley v. Commissioner, 91 T.C. 352, 361 (1988), affd.            
          972 F.2d 150 (7th Cir. 1992).  Petitioner was engaged in a trade            
          or business in some years prior to 1999, but the record does not            
          show that petitioner was engaged in a trade or business during              
          1999.                                                                       
               In addition, with respect to the $312 in travel, $12,374 in            
          car and truck expenses, and $2,018 in meals and entertainment,              
          petitioners are subject to the requirements of section 274.                 
          Section 274(d)(4) provides that such deductions are not allowed             
               unless the taxpayer substantiates by adequate records                  
               or by sufficient evidence corroborating the taxpayer’s                 
               own statement (A) the amount of such expense or other                  
               item, (B) the time and place of the travel,                            





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