Curtis Muhammad - Page 8

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          to respondent on June 5, 2006, the day before trial.  The first             
          page indicates that the document was issued by “Sister LaVerne              
          Muhammad, Delaware Valley Regional Secretary.”  However,                    
          petitioner testified that LaVerne Muhammad is not the current               
          Delaware Valley Regional Secretary.  Petitioner did not provide a           
          statement of charitable contributions from the current regional             
          secretary or any current recordkeeper at the mosque.                        
               Applying the previously mentioned standards for                        
          substantiating deductions for contributions, we find that                   
          petitioner failed to provide reliable evidence of his purported             
          contributions and failed to meet his burden of proof.  We hold              
          that respondent’s determination disallowing petitioner’s claimed            
          charitable contribution deduction is sustained.                             
          B.  Business Expense Deductions Claimed on Schedule C                       
               Section 162(a) permits a taxpayer to deduct expenses paid or           
          incurred during the taxable year in carrying on the taxpayer’s              
          trade or business and requires a taxpayer to prove that the                 
          expenses deducted were:  (1) Paid or incurred during the taxable            
          year; (2) incurred to carry on the taxpayer’s trade or business;            
          and (3) ordinary and necessary expenditures of the business.  See           
          sec. 162(a); Commissioner v. Lincoln Sav. & Loan Association, 403           
          U.S. 345, 352 (1971).                                                       









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