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T.C. 438, 440 (2001); sec. 1.6001-1(a), Income Tax Regs; see also
secs. 274(d), 280F(d)(4).
At trial, petitioner failed to offer any evidence to
substantiate the car and truck expense deductions claimed on the
Schedules C.
As for the substantiation of other expenses on the Schedules
C, petitioner relied on an earnings statement for the period
ending December 15, 2002, which respondent had already examined
and accounted for in the statutory notice of deficiency.
Petitioner testified that he did not maintain any records or
receipts for his other expenses. Although tools were a large
component of petitioner’s other expenses, petitioner claimed that
he lacked documentation, because the tools were paid for in cash
and purchased from friends and coworkers.
Petitioner, instead, presented copies of invoices, receipts,
and sales contracts from 2005, which he contends were the same
type of expenses that he paid in 2002 and 2003. These documents,
however, are not relevant, because they fail to substantiate the
amount of other expenses that petitioner may have paid in 2002
and 2003.
The Court sustains respondent’s determination that
petitioner is not entitled to Schedule C deductions for car and
truck expenses, and other expenses in excess of the amounts
allowed by respondent.
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