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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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