- 5 -
The Court has reviewed the evidence presented by petitioner
and respondent at trial. The Court agrees with respondent’s
determination in the deficiency notice that petitioner has failed
to substantiate that he had a business loss of $10,000 in 1982.
See Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976) (holding that taxpayers bear the
burden of substantiating the amount and purpose of any claimed
deduction). Moreover, even if petitioner had substantiated that
he had a business loss in 1982, that loss would not be deductible
against his income in 2003. See sec. 165; United States v.
Skelly Oil Co., 394 U.S. 678, 684 (1969) (multiple deductions of
the same item are generally precluded).
Accordingly, petitioner is not entitled to claim a Schedule
C business loss deduction of $10,000 for 2003.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6
Last modified: November 10, 2007