- 5 - professional services to GMAC and incurred $967.70 in reimbursable expenses. Petitioner also credibly testified, and provided corroborating bank statements showing, that $19,282 and $19,967.70 were debited from his account on February 13 and March 27, 2003, respectively. On the basis of petitioner’s testimony and corroborating evidence, we conclude that petitioner was merely a conduit for the $39,249. Accordingly, we hold that the $39,249 that petitioner received from GMAC and in turn paid to Ms. Mulvey is not includable in petitioners’ gross income. Regarding the nonreimbursed business expenses petitioners seek to deduct, deductions are a matter of legislative grace. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). The taxpayer bears the burden of proving he is entitled to deductions and must present adequate documentation to support any deductions claimed. Welch v. Helvering, supra at 115; see also Nowland v. Commissioner, 244 F.2d 450, 453 (4th Cir. 1957) (holding the taxpayer bears the “burden of proving the amount of the deductible expenses since deductions are a matter of statutory privilege and must be shown by substantial evidence”). At trial petitioner submitted numerous receipts and documentation substantiating his business expenses for taxable year 2003. With the exception of three automobile payments to Saab FinancialPage: Previous 1 2 3 4 5 6 7 Next
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