Robert and Cheryl McKeown - Page 12

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          legislative grace, and the taxpayer has the burden to prove he or           
          she is entitled to any deduction claimed.  Rule 142(a); Deputy v.           
          du Pont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v.                  
          Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, supra.             
          This includes the burden of substantiation.  Hradesky v.                    
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976).                                                        
               A taxpayer must substantiate amounts claimed as deductions             
          by maintaining the records necessary to establish he or she is              
          entitled to the deductions.  Sec. 6001; Hradesky v. Commissioner,           
          supra.  The taxpayer shall keep such permanent records or books             
          of account as are sufficient to establish the amounts of                    
          deductions claimed on the return.  Sec. 6001; sec. 1.6001-1(a),             
          (e), Income Tax Regs.  The Court need not accept a taxpayer’s               
          self-serving testimony when the taxpayer fails to present                   
          corroborative evidence.  Beam v. Commissioner, T.C. Memo. 1990-             
          304 (citing Tokarski v. Commissioner, 87 T.C. 74, 77 (1986)),               
          affd. without published opinion 956 F.2d 1166 (9th Cir. 1992).              
          Unreimbursed Employee Business Expenses                                     
               We shall now consider whether petitioners are entitled to              
          deduct the claimed expenses, beginning with the unreimbursed                
          employee business expenses petitioners claimed on Schedule A.               
               In general, all ordinary and necessary expenses paid or                
          incurred in carrying on a trade or business during the taxable              

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