- 4 - expense deductions for Mr. Booker’s business. Respondent disallowed the claimed deductions for lack of substantiation. Petitioners also untimely filed their 2000 Federal income tax return on June 7, 2001. On that return, petitioners claimed a dependency exemption deduction for Mrs. Booker’s mother. Petitioners also claimed itemized deductions of $13,405 for charitable contributions and $19,998 for various trade or business expenses deductions in connection with Mr. Booker’s business. Respondent also disallowed these deductions for lack of substantiation. Deductions are a matter of legislative grace, and the taxpayer bears the burden of proving entitlement to any deductions claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). The taxpayer is required to identify each deduction available and show that all requirements have been met. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). It is also the taxpayer’s responsibility to maintain records sufficient to enable the Commissioner to determine the correct tax liability. Sec. 6001; Higbee v. Commissioner, 116 T.C. 438 (2001); sec. 1.6001-1(a), Income Tax Regs. The taxpayer must substantiate both the amount and purpose of claimed deductions. Higbee v. Commissioner, supra. As previouslyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011