Peter Showler - Page 7




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          distinguish among his clients, NPC’s clients, and Wise’s clients,           
          but his attempts, for the most part, were lost on the Court.                
          This lack of detail, exacerbated by a lack of precision, does               
          little to demonstrate how many of the disallowed deductions                 
          relate to petitioner’s trade or business.  Furthermore,                     
          complications between the parties that arose in the pretrial                
          stipulation process, see Rule 91, resulted in a hodgepodge of               
          exhibits, some of which duplicate others in content if not                  
          format, many of which are illegible or incomplete, and many of              
          which, although it might come as a surprise to the parties, are             
          hardly self-explanatory.                                                    
               As we have noted in countless cases, deductions must be                
          substantiated by adequate records.  Sec. 6001; Hradesky v.                  
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976).  Not only does the taxpayer bear the burden            
          to substantiate any deduction claimed, but in proceedings such              
          as this one, the taxpayer has the burden to present the                     
          substantiating records in an organized manner that clearly                  
          demonstrates the relationship of the record to the disputed                 
          deduction.                                                                  
          1. Deductions for Expenses Other Than for Commissions and Fees              
               The documents that petitioner produced to substantiate the             
          deductions claimed for expenses other than for commissions and              
          fees consist of:  (1) Copies of receipts from various restaurants           







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