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OPINION
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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