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his 1997 individual Federal income tax return and an accuracy-
related penalty under section 6662 on the full amount of the tax
deficiency determined by respondent.
OPINION
Taxpayers are expected to keep adequate books and records
reflecting their income and expenses. Sec. 6001.
Generally, under section 7491(a), the burden of proof
on factual issues relating to a taxpayer’s tax liability may
shift from the taxpayer to respondent where the taxpayer has
credible evidence to substantiate the item in question, has
maintained appropriate records relating thereto, and has
cooperated with reasonable requests for information relating to
the item in question. Sec. 7491(a)(1) and (2); Rule 142(a).
Petitioner has not produced credible evidence to
substantiate any of the items at issue, nor has petitioner
maintained appropriate records relating to the deductions at
issue. Therefore, the burden of proof as to each of the issues
in this case remains on petitioner.
State and Local Income Taxes -- $13,853
In general, a taxpayer is allowed an itemized deduction for
State and local taxes paid within a year. Sec. 164(a).
Petitioner has not introduced any credible evidence to
substantiate that during 1997 he paid the $13,853 in State and
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