- 24 -
the employment. See Evans v. Commissioner, T.C. Memo. 1974-267,
affd. 557 F.2d 1095 (5th Cir. 1977). The taxpayer bears the
burden of substantiation. Hradesky v. Commissioner, 65 T.C. 87,
90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).
Petitioner testified that the unreimbursed employee expenses
were paid in furtherance of his occupation as a truck driver.
Once again, petitioner provided no documentation that would
substantiate that he paid the claimed expenses or that the
alleged expenses were related to his employment as a truck
driver.
On the basis of the record in this case, we conclude that
petitioner has not substantiated any unreimbursed employee
expenses for taxable year 2000 in excess of the amount allowed by
respondent. Accordingly, respondent’s determination on this
issue is sustained.
5. Interest Income
Petitioner timely filed his Federal income tax returns for
taxable years 2000 and 2001 without reporting any interest
income. Respondent, in the notice of deficiency, determined that
petitioner received interest income of $113 and $41 for taxable
years 2000 and 2001, respectively.
The law is clear. Gross income includes all income from
whatever source derived. Sec. 61(a). Section 61(a)(4)
specifically includes income derived from interest.
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011