Daniel A. Aregoni - Page 6

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          entitled to the claimed deductions.  INDOPCO, Inc. v.                       
          Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.               
          Helvering, 292 U.S. 435, 440 (1934).  With these well-established           
          propositions in mind, we must determine whether petitioner has              
          satisfied his burden of proving that he is entitled to deductions           
          for job expenses and other miscellaneous deductions in excess of            
          the $19,285 conceded by respondent.                                         
               Section 162(a) allows a deduction for ordinary and necessary           
          business expenses paid or incurred during the taxable year in               
          carrying on any trade or business.  For an expense to be                    
          “ordinary” the transaction that gives rise to the expense must be           
          of a common or frequent occurrence in the type of business                  
          involved.  Deputy v. du Pont, 308 U.S. 488, 495 (1940).  To be              
          “necessary” an expense must be “appropriate and helpful” to the             
          taxpayer’s business.  Welch v. Helvering, supra at 113-114.  The            
          performance of services as an employee constitutes a trade or               
          business.  See sec. 1.162-17(a), Income Tax Regs.  The employee             
          must show the relationship between the expenditures and the                 
          employment.  See Evans v. Commissioner, T.C. Memo. 1974-267.  The           
          taxpayer bears the burden of substantiation.  Hradesky v.                   
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976).  Section 6001 and the regulations                      
          promulgated thereunder require taxpayers to maintain records                
          sufficient to permit verification of income and expenses.  As a             






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