Les B. Martin and Millie A. Martin - Page 9

               Deductions are a matter of legislative grace.  New Colonial            
          Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).  Taxpayers bear the         
          burden of establishing that they are entitled to the claimed                
          deductions.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 114             
          (1933).  This includes the burden of substantiating the amount and          
          purpose of the item claimed.  Sec. 6001; Hradesky v. Commissioner,          
          65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.              
          1976); sec. 1.6001-1(a), Income Tax Regs.  If claimed deductions            
          are not adequately substantiated, we may estimate them, provided we         
          are convinced that the taxpayer has incurred such expenses and we           
          have a basis upon which to make an estimate.  Cohan v.                      
          Commissioner, 39 F.2d 540 (2d Cir. 1930); Vanicek v. Commissioner,          
          85 T.C. 731, 743 (1985).                                                    
          Moving Expenses                                                             
               Section 217 permits a deduction for moving expenses paid or            
          incurred during the  taxable  year  in  connection  with  the               
          commencement of work by the taxpayer as an employee at a new                
          principal place of work.  To qualify as being in connection with            
          the commencement of work, the move must be reasonably proximate             
          both in time and place to the commencement of work at the new               
          workplace.  In general, moving expenses incurred within 1 year of           
          the commencement of work are considered to be reasonably proximate          
          in time to such commencement.  Moving expenses incurred after the           
          1-year period may be considered reasonably proximate in time if             

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