- 6 - 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 restaurantsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: March 27, 2008