- 12 - invoices that petitioner submitted to PSEG Global on which he requested reimbursement for expenses totaling $19,548. PSEG Global’s records indicate that the company paid all but $2,360 of these expenses in accordance with petitioner’s requests for payment. Petitioner, however, claimed deductions for numerous expenses on his Schedule C, in an amount totaling $123,040. Respondent has not challenged $106,040 of these deductions, some of which are for expenses that are of the same type as those for which petitioner requested reimbursement from PSEG Global. Because petitioner’s Schedule C was filed for his consulting business, and PSEG Global was the primary source of income for this business, we conclude that the Schedule C deductions substantially encompass the expenses for which petitioner was reimbursed by PSEG Global. A taxpayer is not entitled to both exclude an amount from income as a reimbursement of an expense and then deduct the same amount as a business expense. See generally sec. 1.161-1, Income Tax Regs. (providing that “Double deductions are not permitted”.). Because petitioner has failed to provide records of any sort supporting the amount of his deductions, the Court cannot ascertain whether the $17,188 in reimbursements petitioner received is wholly reflected in the $106,040 of allowed expenses that he claimed as deductions on his return. We conclude that petitioner has failed to show either that he is entitled to exclude from income any portion of the reimbursements he receivedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011