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they placed in service during 1986, petitioners contend that they
are entitled to a general business credit carryforward from 1986
with respect to those properties. Respondent determined that
petitioners are not entitled to that credit because they failed
to establish that they had a credit from 1986 to carry forward.
Credits are a matter of legislative grace, and taxpayers
must prove their entitlement to them. Rule 142(a); Segel v.
Commissioner, 89 T.C. 816, 842 (1987). A taxpayer is required to
maintain records as long as the contents of those records may
become material in the administration of any internal revenue
law. Sec. 1.6001-1(e), Income Tax Regs. If a credit affects the
calculation of tax due for an open year, respondent is entitled
to recalculate the amount of credits earned and/or used for a
particular year even if the period of limitations has expired for
that year. Hill v. Commissioner, 95 T.C. 437, 445-446 (1990);
Mennuto v. Commissioner, 56 T.C. 910, 923 (1971).
Petitioners have failed to establish that they had a general
business credit from 1986 to carry forward. For 1986, section
38(a)(2) allows a credit for, inter alia, the amount of the cur-
rent year business credit. Section 38(b) defines the term "cur-
rent year business credit" to include the investment credit
determined under section 46(a). Sec. 38(b)(1). Section 46 de-
fines the amount of the investment credit to include the regular
percentage of the qualified investment determined under section
46(c). Sec. 46(a)(1). Section 46(c)(1) provides that the term
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