- 4 - he said. Petitioner testified that in moving from New York to Puerto Rico he lost “nine boxes of documents”. He testified that the amounts deducted on the return are estimates. Petitioner, however, failed to explain how he arrived at his estimates. This Court is not bound to accept a taxpayer’s unverified and self-serving testimony. Blodgett v. Commissioner, 394 F.3d 1030, 1036 (8th Cir. 2005), affg. T.C. Memo. 2003-212; Shea v. Commissioner, 112 T.C. 183, 189 (1999). Because petitioner has failed to corroborate his testimony or provide any substantiation to support his itemized deductions, we sustain respondent’s position with respect to the itemized deductions. 2. Schedule C Expenses Section 162 generally allows a deduction for ordinary and necessary expenses paid or incurred during the taxable year in carrying on a trade or business. Generally, no deduction is allowed for personal, living, or family expenses. See sec. 262. The taxpayer must show, Rule 142(a), that any claimed business expenses were incurred primarily for business rather than social reasons, see Walliser v. Commissioner, 72 T.C. 433, 437 (1979). To show that the expense was not for personal reasons, the taxpayer must show that the expense was incurred primarily to benefit his business, and there must have been a proximate relationship between the claimed expense and the business. See id.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011