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years at issue.3 In an attempt to support that claim, petitioner
introduced into evidence at trial lists that he had prepared of
such alleged expenses. However, petitioner failed to proffer
into evidence any documentation or other evidence establishing
that he incurred the claimed expenses and that any expenses that
he did incur are deductible. On the record before us, we find
that petitioner has failed to establish that he is entitled to
deduct any expenses for the years at issue.
Based on the entire record before us, we find that, except
to the extent stated herein, petitioner has not satisfied his
burden of showing error in any of respondent's determinations in
the notices.
To reflect the foregoing,
Decision will be entered
under Rule 155.
3 Although not altogether clear, it appears that petitioner may
be arguing that respondent's determination that petitioner is not
entitled to the deductions that he claimed in his 1992 return is
arbitrary. To the extent petitioner is making that argument, he
is wrong. Deductions are a matter of legislative grace, and the
taxpayer has the burden of showing that such taxpayer is entitled
to any deduction claimed. INDOPCO, Inc. v. Commissioner, 503
U.S. 79, 84 (1992).
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