2024-06-10
Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle), today's tax quote is:
Petitioner has failed to show that he has satisfied all of his relevant burdens with respect to any claimed trade or business item. Indeed, it is not clear that petitioner has shown that he has satisfied any burden with respect to any trade or business item. Petitioner has chosen to rely on what may be termed the "shoebox method" of attaching photocopies of numerous cash register tapes and of similar bits of paper to his returns, without making any effort on the returns or on brief, and only a slight effort in oral testimony, to link any item to a deductible trade or business expense transaction. Petitioner appears to have wholly ignored the admonitions made by this Court on the previous occasions when he sought similar deductions.
Patterson v. Commr., T.C. Memo. 1979-362.