- 17 - We find that respondent has proven by clear and convincing evidence that Sam Kong Fashions received and failed to report gross receipts in 1994 and 1995. On the basis of the customers’ payments for sewing services, we find that Sam Kong Fashions received total gross receipts of $616,574.25 in 1994 and $521,214.64 in 1995. On its corporate income tax returns, Sam Kong Fashions reported gross receipts in the amount of $224,718 and $217,296 in 1994 and 1995, respectively. Therefore, we find, by clear and convincing evidence, that the unreported gross receipts of Sam Kong Fashions totaled $391,856.25 in 1994 and $303,918.64 in 1995. B. Unreported Business Expenses Section 162(a) provides a deduction for all ordinary and necessary expenses paid or incurred in carrying on a trade or business. Taxpayers bear the burden of proving that they are entitled to any claimed deductions. Rule 142(a); INDOPOC, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Section 6001 provides that a taxpayer must substantiate any deductible expenses claimed. Taxpayers are required to maintain records that sufficiently establish the amount of claimed deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. When taxpayers present convincing evidence that they incurred deductible expenses, but lack the records to substantiate the claimed amounts, courts may estimate the allowable deductions.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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