John K. Jorman, Jr. and Audrey Jorman - Page 7

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          440 (1934); Welch v. Helvering, supra.  In addition, a taxpayer             
          is required to keep books or records to substantiate all                    
          deductions which are claimed.  Sec. 6001; sec. 1.6001-1(a),                 
          Income Tax Regs.  Where a taxpayer fails to produce any records             
          to substantiate his deductions, disallowance of the claimed                 
          deductions is proper.  Williams v. Commissioner, T.C. Memo. 1986-           
          Moving Expense Deduction                                                    
               Ordinarily, moving expenses are considered nondeductible               
          family and living expenses.  However, subject to certain                    
          requirements neither relevant nor in dispute in this case,                  
          section 217 permits a deduction for all reasonable moving                   
          expenses paid or incurred during the taxable year in connection             
          with the commencement of work as an employee at a new principal             
          place of work.  Whether a claimed moving expense is reasonable is           
          a question of fact to be determined under the circumstances of              
          the particular move.  Sec. 1.217-2(b)(2), Income Tax Regs.  A               
          taxpayer is required to prove the expenses incurred.  See                   
          Haberthier v. Commissioner, T.C. Memo. 1984-377.  Petitioners'              
          proof in support of the disputed moving expense deduction                   
          consists of petitioner's testimony and records from PSI relating            
          to the amount of relocation benefits petitioner received.  After            

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