James A. and Joan H. Soholt - Page 7




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          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 amount 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).              
               We shall now proceed to consider whether petitioners are               
          entitled to deduct the claimed expenses, beginning with                     
          petitioners’ charitable contributions of cash and property.                 
          Charitable Contributions                                                    
               Petitioners claimed they contributed $6,897 of cash to                 
          charitable organizations in 2003, and respondent allowed all but            
          $232 based on receipts from donee organizations as well as                  







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