Darryl R. and Kristi L. Stephens - Page 12




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          taxpayer 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 amounts 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).              
               Charitable contributions a taxpayer makes are generally                
          deductible under section 170(a).  No deduction is allowed,                  
          however, for any contribution of $250 or more unless the taxpayer           
          substantiates the contribution by a contemporaneous written                 
          acknowledgment of the contribution by a qualified donee                     










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