-6- seeks or shown that he has maintained sufficient records. Sec. 7491(a)(2)(A) and (B). In his petition, petitioner claimed that respondent erred by not computing his deductions for Schedule C expenses, Schedule A interest, charitable contributions, and property taxes paid during the years in issue, but he did not state how much these expenses amounted to. As evidence that he is entitled to deductions, petitioner introduced two summaries of his expenses during the years in issue. The summaries contain general captions such as “PHONE”, “DONATIONS”, and “AM EXP GOLD”, the amounts of the expenses, and usually dates for each expense. However, the summaries provide no indication of which expenses were for business purposes and which were for personal purposes, and it is not clear which of the expenses petitioner is seeking to deduct. Petitioner credibly testified that he paid commissions to business associates in exchange for referrals, and the names of these associates match some of the captions on the expense summaries. On the basis of this evidence and information that petitioner provided while negotiating with respondent, respondent concedes that under section 162(a) petitioner is entitled to $214,645, $122,520, $239,965, $82,986, and $29,904 of Schedule C business expense deductions for commissions and FOIA request fees paid for taxable years 1999, 2000, 2001, 2002, and 2003,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008