Richard Lewis Field - Page 5

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          Commissioner, 503 U.S. 79, 84 (1992).  Taxpayers bear the burden            
          of substantiating the amount and purpose of any claimed                     
          deduction.  See Hradesky v. Commissioner, 65 T.C. 87 (1975),                
          affd. per curiam 540 F.2d 821 (5th Cir. 1976).  Taxpayers are               
          required to maintain sufficient records to establish the amounts            
          of income and deductions.  Sec. 6001; Higbee v. Commissioner, 116           
          T.C. 438, 440 (2001); sec. 1.6001-1(a), Income Tax Regs.                    
               Both sections 162 and 212 allow deductions for ordinary and            
          necessary expenses paid or incurred during the taxable year.                
          Section 162(a) requires that the expenses be paid or incurred in            
          carrying on a trade or business.  Section 212 requires only that            
          the expenses be paid or incurred for the production or collection           
          of income, or for the management, conservation, or maintenance of           
          property held for the production of income.  Sec. 212(1) and (2).           
               For 2000, petitioner listed seven activities on his Schedule           
          C: (1) Richard L. Field, Ph.D., Consulting Engineer, a solar                
          energy consulting activity; (2) Sol Pub Co., which involved sales           
          of solar books; (3) Field Investment Management; (4) Field Oil              
          and Gas; (5) Field Vehicle Sales; (6) Field Real Estate; and (7)            
          Field Entertainment.  Petitioner admits that he had no income or            
          expenses for the oil and gas, real estate, and entertainment                
          activities in 2000 and that he should not have included them on             
          Schedule C.  The parties agree that Sol Pub Co. and Field Vehicle           







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