Daniel J. and Joyce A. Roderick - Page 6

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          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 Financial                







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