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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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Last modified: November 10, 2007