- 6 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011