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petitioner refused to provide records, invoking Fifth Amendment).
For the foregoing reasons, we reject petitioner's assertions.
Petitioner also contends that respondent, in the course of
the examination, abridged petitioner's copyright interest in a
1993 article entitled, "The Audit of '91". Petitioner's
copyright infringement claims have no foundation. Respondent is
entitled to examine petitioner's literary works in order to
establish whether there was a connection between petitioner's
claimed business deductions and petitioner's business as a
writer. Accordingly, we reject petitioner's arguments.
2. Schedule C Deductions
We now turn to the question of whether petitioner may
properly claim the deductions in question. As explained supra,
petitioner bears the burden of proving entitlement to any claimed
deductions. In this regard, taxpayers must keep sufficient
records to establish the amount of deductions or other matters
required to be shown on the taxpayer's return. Sec. 1.6001-1(a),
Income Tax Regs.
Section 162(a) generally allows a deduction for "ordinary
and necessary" expenses incurred while carrying on a trade or
business. Respondent does not appear to question that
petitioner's writing activities constitute a "trade or business".
Respondent, however, argues that petitioner has failed to prove
that the deductions claimed are "ordinary and necessary" expenses
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