- 12 - Respondent's determinations are presumed correct, and petitioners bear the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions are a matter of legislative grace, and taxpayers bear the burden of proving that they are entitled to any deduction claimed. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers must substantiate the amount of any deductions claimed. Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). Taxpayers are required to keep sufficient records to enable the Commissioner to determine their correct tax liability. Sec. 6001. Section 162 allows the deduction of ordinary and necessary expenses incurred in carrying on any trade or business. Section 212 allows the deduction of ordinary and necessary expenses for the production or collection of income or for the maintenance of property held for the production of income. Petitioners failed to substantiate their entitlement to deductions in an amount in excess of that already allowed by respondent. They did not produce records of Double D Ranch, Inc., such as journals, 13(...continued) 1984 1985 1986 Total income reported by $1,500 $0 $18,817 Double D Ranch, Inc. Less: Total interest paid (71,644) (69,590) (58,228) Total real estate taxes paid (7,107) (5,493) (5,840) Total loss allowed ($77,251) ($75,083) ($45,251)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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