- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011