Richard Walter Drake - Page 5

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          exception of supplies in the amount of $78.  As a result of these           
          adjustments, respondent increased petitioner's taxable income by            
          $17,806.  Respondent disallowed petitioner's deduction for an IRA           
          contribution in full.  In addition, respondent determined that              
          petitioner was liable for an accuracy-related penalty of $534               
          pursuant to section 6662(a) for negligence or intentional                   
          disregard of rules or regulations.                                          
               At trial, petitioner filed a Schedule A for 1993 claiming              
          deductions for mortgage interest of $3,407, real estate taxes of            
          $1,913, charitable contributions of $300, and miscellaneous                 
          expenses of $1,050 before the 2-percent floor.  The Court filed             
          this document as petitioner's amendment to petition.                        
               Respondent's determinations are presumed to be correct, and            
          the burden is on petitioner to prove that the determinations are            
          erroneous.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115              
          (1933).  Further, deductions are a matter of legislative grace,             
          and petitioner must prove entitlement to any deductions claimed.            
          INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).  A                   
          taxpayer must maintain adequate records to substantiate the                 
          amount of any deductions claimed.  Sec. 6001; sec. 1.6001-1(a),             
          Income Tax Regs.                                                            
               Generally, when evidence shows that a taxpayer has incurred            
          a deductible expense, but the exact amount cannot be determined,            
          the Court may approximate the amount.  Cohan v. Commissioner, 39            






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