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ground that petitioners failed to establish that such expenses
constitute ordinary and necessary business expenses.
OPINION
Respondent's determinations, having been made in a notice of
deficiency, are presumptively correct, and petitioners bear the
burden of proving that such determinations are erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are matters of legislative grace. A taxpayer who claims a
deduction must identify the specific statute which allows for the
type of deduction being claimed, and the taxpayer must
demonstrate that he or she satisfies all of the requirements or
conditions set forth in the statute. Rule 142(a); INDOPCO, Inc.
v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, supra.
Home Office Deduction
In general, section 162 allows deductions for ordinary and
necessary expenses incurred by a taxpayer in carrying on a trade
or business. Sec. 162(a). Petitioner's medical practice
constitutes a trade or business within the meaning of section
162. See Commissioner v. Groetzinger, 480 U.S. 23 (1987). The
general rule provided by section 162(a) is qualified by various
limitations, including one that prohibits otherwise allowable
deductions "with respect to the use of a dwelling unit which is
used by the taxpayer during the taxable year as a residence."
Sec. 280A(a). The dwelling unit involved in this case, namely
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