- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011