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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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