Dixon
Dixon v. Commissioner
Opinion
Lead Opinion
MEMORANDUM **
Michel L. Dixon appeals pro se the tax court’s decision, following a bench trial, upholding the Commissioner of Internal Revenue’s determination of federal income tax deficiencies and a penalty under 26 U.S.C. § 6651 (a)(1). We have jurisdiction pursuant to 26 U.S.C. § 7482 (a)(1), and we affirm.
*470 We review tax court evidentiary decisions for an abuse of discretion, Hudspeth v. Commissioner, 914 F.2d 1207, 1213 (9th Cir.1990), and questions of fact for clear error, Boyd Gaming Corp. v. Commissioner, 177 F.3d 1096, 1098 (9th Cir.1999).
Dixon has not demonstrated that the tax court abused its discretion by excluding the exhibits not identified 15 days before trial, as required in the pretrial order, nor has he demonstrated any prejudice. See Alexander Shokai, Inc. v. Commissioner, 34 F.3d 1480, 1488 (9th Cir.1994).
Because Dixon failed to substantiate by adequate records the amount of his travel expenses, the time and place of the expenses, and the business purpose of the expenses, the tax court correctly rejected Dixon’s claimed deduction for traveling expenses. See 26 U.S.C. § 274 (d); Meridian Wood Prods. Co. v. United States, 725 F.2d 1183, 1188 (9th…