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Section 6001 requires generally that every person liable for
any tax keep such records, render such statements, make such
returns, and comply with such regulations as the Secretary may
from time to time prescribe. Section 1.6001-1(a), Income Tax
Regs., provides, in pertinent part, that “any person subject to
tax under subtitle A of the Code * * *, shall keep such permanent
books of account or records, including inventories, as are
sufficient to establish the amount of gross income, deductions,
credits, or other matters required to be shown by such person in
any return of such tax”.
After careful consideration of the evidence presented,
including petitioner’s testimony and the concessions by
respondent, the Court is not inclined to go beyond what
respondent has conceded. Accordingly, this Court holds that
petitioner is not entitled to any deductions in excess of the
amounts allowed and conceded by respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011