Bamidele Arike Kolapo - Page 6

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          claimed deduction.  Rule 142(a); INDOPCO, Inc. v. Commissioner,             
          503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292              
          U.S. 435, 440 (1934).  Taxpayers are required to maintain records           
          that are sufficient to enable the Commissioner to determine their           
          correct tax liability.  See sec. 6001; sec. 1.6001-1(a), Income             
          Tax Regs.  Additionally, taxpayers bear the burden of                       
          substantiating the amount and purpose of each item they claimed             
          as a deduction.  See Hradesky v. Commissioner, 65 T.C. 87, 89               
          (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).                      
               Section 162 generally allows a deduction for all the                   
          ordinary and necessary expenses paid or incurred during the                 
          taxable year in carrying on any trade or business.  Such expenses           
          must be directly connected with or pertain to the taxpayer’s                
          trade or business.  Sec. 1.162-1(a), Income Tax Regs.  A trade or           
          business includes the trade or business of being an employee.               
          O’Malley v. Commissioner, 91 T.C. 352, 363-364 (1988); sec.                 
          1.162-17(a), Income Tax Regs.  Whether an expenditure satisfies             
          the requirements of section 162 is a question of fact.                      
          Commissioner v. Heininger, 320 U.S. 467, 475 (1943).                        
               Respondent argues that petitioner has failed to substantiate           
          the claimed miscellaneous expenses remaining in dispute.  The               
          only records petitioner produced at trial were logs of her                  
          estimated mileage, cell phone expenses, and cleaning expenses,              

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