5
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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