Gregory A. Maslow and Marina Maslow - Page 10

               Deductions are a matter of legislative grace, and in general           
          taxpayers bear the burden of proving that they are entitled to the          
          deductions claimed.  Rule 142(a); INDOPCO, Inc. v. Commissioner,            
          503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S.         
          435 (1934).  Taxpayers must keep sufficient records to establish            
          the amount of their deductions.  See sec. 6001; Meneguzzo v.                
          Commissioner, 43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income         
          Tax Regs.  Moreover, a taxpayer who claims a deduction bears the            
          burden of substantiating the amount and purpose of the item                 
          claimed.  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.                                                                   
               Because petitioner failed to substantiate his purported travel         
          costs, we sustain respondent's disallowance of the $7,220 in                
          question.  Moreover, insofar as the purported travel expenses               
          represent startup business costs, they would not be deductible in           
          1992 because petitioner's export business did not begin operations          
          until 1993.  See sec. 195; Garrett v. Commissioner, T.C. Memo.              
               C. Insurance Expenses                                                  
               Respondent disallowed the claimed insurance expenses on the            
          basis that petitioner failed to substantiate the business purpose           
          of the deduction.  Petitioner claims the insurance expenses related         
          to his automobile insurance; respondent, on the other hand, asserts         
          petitioner told Revenue Agent Bank that the insurance was for his           

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