Michael Joseph Major - Page 6

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                                       OPINION                                        
          A.   Whether Petitioner May Deduct More Business Expenses Than              
               Respondent Allowed for 1999 and 2000                                   
               Petitioner contends that he may deduct more expenses for his           
          journalism activity for 1999 and 2000 than respondent allowed               
          ($3,720 for 1999 and $7,650 for 2000).  We disagree.                        
               A taxpayer must keep records that are sufficient to enable             
          the Commissioner to determine his or her tax liability.  See sec.           
          6001; sec. 1.6001-1(a), Income Tax Regs.  A taxpayer must                   
          substantiate the payments which give rise to claimed deductions.            
          Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam           
          540 F.2d 821 (5th Cir. 1976); see sec. 6001.  Petitioner has the            
          burden of establishing that he is entitled to the deductions                
          claimed.4  See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84               
          (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                
          (1934).                                                                     
               Petitioner did not offer any evidence that he was entitled             
          to deduct more business expenses for 1999 and 2000 than                     
          respondent allowed.                                                         
               Petitioner urges this Court to allow him to deduct the                 
          amounts he had deducted on his tax returns, and he contends his             
          deductions were reasonable.  However, it is not enough that                 

               4 The burden of proof for a factual issue may shift to the             
          Commissioner under certain circumstances.  Sec. 7491(a).                    
          Petitioner does not contend that he meets the requirements of               
          sec. 7491(a), however.                                                      





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