- 26 - $8,500 was not income to SCC. The second is a deposit of $8,500 on August 16, 1994, which Mr. Strong claims was payment for the sale of his truck to his brother. In this instance, SCC has not carried its burden. Mr. Strong provided testimony from his brother that the $8,500 deposit was payment for a pickup truck. However, this testimony is inconsistent with the records of the Minnesota Department of Motor Vehicles regarding the ownership of the truck in question, and we find this testimony unconvincing. SCC does not provide any explanation for the remaining deposits, and we conclude that these deposits are income to SCC. C. Allowable Expenses of SCC Section 162(a) allows a taxpayer deductions for ordinary and necessary business expenses incurred during the taxable year in carrying on a trade or business. Deductions, however, are a matter of legislative grace, and the taxpayer bears the burden of proving entitlement to any deduction claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Generally, a taxpayer must establish that deductions taken pursuant to section 162 are ordinary and necessary business expenses and must maintain records sufficient to substantiate the amounts of the deductions claimed. Sec. 1.6001-1(a), Income Tax Regs. With respect to certain business expenses specified in section 274(d), more stringent substantiation requirements apply. Section 274(d) disallows deductions for travel expenses, gifts,Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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