-5-
respondent determined that such expenses were not substantiated.
Respondent disallowed the deduction for the cost and maintenance
of uniforms as not being an ordinary and necessary business
expense. Respondent disallowed all but $5 of petitioners'
charitable contribution deduction for lack of substantiation.
Finally, respondent determined that because petitioners did not
file their 1991 Federal income tax return until July 24, 1992,
they were liable for the late filing addition to tax under
section 6651(a)(1).
Discussion
Respondent's determinations are presumed correct, and
petitioners bear the burden of proving otherwise. Rule 142(a);
Welch v. 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. Rule 142(a); 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).
1. Employee Business Expenses
a. Vehicle Expenses
Petitioners claim deductions for their vehicle expenses as
unreimbursed employee business expenses. Section 162(a) allows a
deduction for all ordinary and necessary expenses incurred in
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