Hans H. and Cheryl E. Hammann - Page 22

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          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) made                




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