This case has been cited 2 times or more.
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2013-07-29 |
BERSAMIN, J. |
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| The rule that tax deductions, being in the nature of tax exemptions, are to be construed in strictissimi juris against the taxpayer is well settled.[20] Corollary to this rule is the principle that when a taxpayer claims a deduction, he must point to some specific provision of the statute in which that deduction is authorized and must be able to prove that he is entitled to the deduction which the law allows.[21] An item of expenditure, therefore, must fall squarely within the language of the law in order to be deductible.[22] A mere averment that the taxpayer has incurred a loss does not automatically warrant a deduction from its gross income. | |||||
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2007-02-12 |
YNARES-SANTIAGO, J. |
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| The requisites for the deductibility of ordinary and necessary trade, business, or professional expenses, like expenses paid for legal and auditing services, are: (a) the expense must be ordinary and necessary; (b) it must have been paid or incurred during the taxable year; (c) it must have been paid or incurred in carrying on the trade or business of the taxpayer; and (d) it must be supported by receipts, records or other pertinent papers.[11] | |||||