Burden is on Taxpayer to Substantiate Deductions.

The petitioner worked for Dupont in recruiting and human relations from 1968 to 1992, when he retied and created an S corporation through which, as a contractor, he offered many of the same services that he performed as an employee of Dupont.  Over the years, the s corporation income declined significantly, but the S corporation still had significant deductions. The IRS disallowed many of the deductions for lack of substantiation.  The court largely agreed with the IRS on the basis that the petitioner failed to show that the claimed deductions were ordinary and necessary expenses for the S corporation.  Instead, many of the expenses were for personal items.  The petitioner's automobile was also found to be used primarily for personal reasons and the petitioner failed to substantiate the extent of business use.  Consequently, only a small portion of claimed business deductions were  allowed.  Moyer v. Comr., T.C. Memo. 2015-45.

CALT does not provide legal advice. Any information provided on this website is not intended to be a substitute for legal services from a competent professional. CALT's work is supported by fee-based seminars and generous private gifts. Any opinions, findings, conclusions or recommendations expressed in the material contained on this website do not necessarily reflect the views of Iowa State University.

RSS​ Facebook Twitter