- 22 - Except as otherwise provided, gross income includes all income from whatever source derived, including interest income. Sec. 61(a)(4); sec. 1.61-7, Income Tax Regs. Petitioners have presented no evidence to challenge respondent's determination on this issue, and accordingly, we hold for respondent. Hans Hammann's Journalism Activity As indicated above, deductions are a matter of legislative grace, and the taxpayer bears the burden of proving that he or she is entitled to any deduction claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. at 440; Welch v. Helvering, supra at 115. This includes the burden of substantiation. Hradesky v. Commissioner, 65 T.C. at 90. Deductions for travel and entertainment are subject to the more stringent substantiation requirements imposed by section 274(d). Petitioners have not presented any evidence to show that the travel and entertainment expenses deducted in 1983 were ordinary and necessary expenses incurred in carrying on a trade or business. In addition, petitioners have not carried their burden of proof with respect to the substantiation requirements imposed by section 274(d). Accordingly, we sustain respondent's determination on this point. Charitable Contribution Deduction Section 170 provides for the allowance as a deduction of any charitable contribution as defined under section 170(c) madePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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