Veronica Chu - Page 7

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          petitioner for $836,540.  Petitioner also testified that she had            
          balance sheets for Topaz.  Petitioner did not submit any                    
          documents related to the calculation of her Topaz stock basis.              
               Petitioner has not provided evidence sufficient to establish           
          her Topaz stock basis.  Therefore, petitioner has not established           
          that she is entitled to deduct the carryover loss on her 2000               
          Federal income tax return.                                                  
               C.   Itemized Deductions                                               
               Petitioner argues that she is entitled to deductions for               
          State income taxes and unreimbursed employee expenses.                      
          Deductions are a matter of legislative grace, and petitioner                
          bears the burden of proving that she is entitled to the                     
          deductions claimed.  See Rule 142(a); INDOPCO, Inc. v.                      
          Commissioner, 503 U.S. 79 (1992); New Colonial Ice Co. v.                   
          Helvering, 292 U.S. 435 (1934).  Taxpayers are required to                  
          maintain records that are sufficient to enable the Commissioner             
          to determine their correct tax liability.  See sec. 6001; sec.              
          1.6001-1(a), Income Tax Regs.  In addition, the taxpayer bears              
          the burden of substantiating the amount and purpose of the item             
          for the claimed deduction.  See Hradesky v. Commissioner, 65 T.C.           
          87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).               
                    1.   State Income Taxes                                           
               Petitioner claimed a $15,749 deduction for State income                
          taxes paid during 2000.  Section 164(a)(3) provides, inter alia,            






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