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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,
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Last modified: March 27, 2008