- 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 received
Page: 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