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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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Last modified: May 25, 2011