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section 7491. Therefore, the burden of proof remains on
petitioners for 1998 and 1999.
a. Car and Truck Expenses
A taxpayer may be allowed to deduct all ordinary and
necessary expenses paid or incurred during the taxable year.
Sec. 162(a). Deductible business expenses include actual
operating expenses of automobiles used in the trade or business
and traveling expenses while away from home solely in the pursuit
of a trade or business. Sec. 1.162-1(a), Income Tax Regs.
Although generally a taxpayer is required to keep records to
establish the amount of his deductions under section 6001 and
section 1.6001-1(a), Income Tax Regs., if there is evidence that
deductible expenses were incurred, the Court may estimate the
amount of expenses and allow a deduction based upon an
approximation of expenses, notwithstanding the lack of
substantiating documentary evidence in the record. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985).
Deductions claimed with respect to certain expenses are
subject to additional substantiation requirements as provided
under section 274. No deduction or credit shall be allowed under
section 162 with respect to, among other items, any listed
property, as defined under section 280F(d)(4), unless the
taxpayer substantiates the expense. Sec. 274(d); sec. 1.274-
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