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claimed. Meals expenses at $3,900 was the next largest item
claimed on Schedule F for 1993, leaving $1,500 for repairs,
maintenance, and supplies accounting for the balance. The 1991
and 1992 Schedules F are substantially similar in amount and
proportion.
Petitioners failed to substantiate the car and truck or
meals expenses claimed, and accordingly it is not necessary to
give them further consideration. Petitioner contended that the
travel was for about three weekly 300-mile round trips from the
location of his employment as a teacher to the farm, where his
wife generally resided. Petitioner contended that those trips
were to work on his tree-farming activity.
Section 162(a) allows a deduction for "ordinary and
necessary" expenses paid or incurred during the taxable year in
carrying on a trade or business. Sanford v. Commissioner, 50
T.C. 823, 826 (1968), affd. per curiam 412 F.2d 201 (2d Cir.
1969). An ordinary and necessary expense is one that is
appropriate and helpful to the taxpayer's business and that
results from an activity which is a common and accepted practice.
Boser v. Commissioner, 77 T.C. 1124, 1132 (1981).
Deductions are a matter of legislative grace, and
petitioners bear the burden of proving that they are entitled to
the deductions claimed. Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435 (1934). Taxpayers must keep sufficient
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