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burden of proving otherwise. Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933). Moreover, deductions are strictly a
matter of legislative grace, and petitioner bears the burden of
proving her entitlement to any 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, 440 (1934).
Section 162(a) allows a deduction for the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Although we will address each
of petitioner's claimed business expense deductions separately,
infra, we generally find that petitioner's testimony was entirely
credible and do not hesitate to rely on it. Petitioner appeared
at trial in possession of well-organized written documentation of
all of the claimed expenses. In our view, respondent's counsel
accepted her testimony as adequate substantiation in light of his
repeated failure to ask her to corroborate her testimony with
documentary evidence. Moreover, the statutory notice of
deficiency does not reveal respondent's basis for the blanket
disallowance of the claimed deductions. Significantly,
respondent's counsel was unable to state, at trial, whether or
not substantiation of the amounts claimed was an issue in the
case. We, therefore, only address the question of whether she is
entitled to deductions for the amounts paid.
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