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question." Simpson Financial Services, Inc. v. Commissioner,
T.C. Memo. 1996-317. We have stated on many occasions that
deductions are strictly a matter of legislative grace. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers must
substantiate any deductions claimed through sufficient records.
Sec. 6001; Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976).
Respondent's position was based on the examination of
petitioner's return. In the notice of deficiency issued to
petitioner following the examination, respondent allowed $5,919
of the claimed $23,276 in deductions. The difference of $17,357
was disallowed because of petitioner's failure to substantiate
the remaining items on her return.
This was only a substantiation case. Although petitioner
repeatedly stated in her petition that she had additional
documents or adequate evidence to substantiate the claimed
deductions, there is no evidence in the record that suggests that
the necessary documents were available to respondent until
approximately 7 months after respondent filed the answer. Prior
to the issuance of the notice of deficiency, petitioner admitted
in her August 21, 1996 letter to respondent that "most of my
original expenditure documents have been misplaced or destroyed
* * * . Therefore, I must rely on your reasonable judgment by
extrapolating from documents enclosed and professional
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