Hoora Rahimi and Isaac William Hammond - Page 9

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          Helvering, 290 U.S. 111, 115 (1933).  Moreover, deductions are a            
          matter of legislative grace, and petitioners bear the burden of             
          proving that they are entitled to any deduction claimed.  New               
          Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v.           
          Helvering, supra at 115.  This includes the burden of                       
          substantiation.  Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),           
          affd. per curiam 540 F.2d 821 (5th Cir. 1976).                              
          A.  Petitioners' Schedule C Expenses                                        
               It is well settled that a corporation is an entity distinct            
          from its shareholders.  Moline Props., Inc. v. Commissioner, 319            
          U.S. 436 (1943); Dalton v. Bowers, 287 U.S. 404, 410 (1932).                
          Furthermore, the business of a corporation is separate and                  
          distinct from the business of its shareholders.  Moline Props.,             
          Inc. v. Commissioner, supra; Deputy v. DuPont, 308 U.S. 488, 494            
          (1940); Crook v. Commissioner, 80 T.C. 27, 33 (1983), affd.                 
          without published opinion 747 F.2d 1463 (5th Cir. 1984).                    
          Consequently, a shareholder is not entitled to a deduction for              
          the payment of corporate expenses.  Deputy v. DuPont, supra at              
          494; Hewett v. Commissioner, 47 T.C. 483 (1967).  Petitioner                
          incorporated ARA in Indiana in June 1999 and accordingly would              
          not be entitled to deduct ARA's expenses.                                   
               To the extent that the claimed deductions related to                   
          petitioner's employment at the university and IIEM, they were not           
          substantiated, as petitioners failed to substantiate any of the             






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