- 254 -
sole proprietorship. Although he continued to utilize CTC for
bookkeeping purposes, petitioner has not shown that any expenses
reflected in CTC's books bear any relationship to CTC's business.
Indeed, it is unclear in what, if any, business CTC engaged
during the years from 1978 through 1981.
It is established law that deductions are a matter of
legislative grace and the taxpayer must meet the specific
statutory requirements for any deduction claimed. Welch v.
Helvering, 290 U.S. at 115; New Colonial Ice Co. v. Helvering,
292 U.S. at 440. It was petitioner's burden to prove his
entitlement to the deductions at issue. Based on this record, we
hold that petitioner failed to prove that he is entitled to any
travel and entertainment expense deductions for the years in
issue other than those allowed by respondent.
VII. Issue 11--Dependency Exemption and Charitable Contribution
Deductions
A. Dependency Exemption
Respondent disallowed dependency exemption deductions for
Tara Daneshvari claimed by petitioner for 1973 and 1974. Tara
was the daughter of petitioner's Iranian friends who lived in
Columbus, Ohio. The issue is whether Tara qualified as
petitioner's dependent during those years.
Section 151(a) and (c) allows a taxpayer, subject to certain
requirements, a deduction for personal exemptions for each of his
dependents as defined in section 152. Pursuant to section
Page: Previous 244 245 246 247 248 249 250 251 252 253 254 255 256 257 258 259 260 261 262 263 NextLast modified: May 25, 2011