Michael E. and Nancy Hentges - Page 7

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          his computer.  Some of these receipts, he acknowledged, were lost           
          in the washing of his clothes.  He asserted he made no claim for            
          such lost receipts on his 1992 return.                                      
               All taxpayers are required to keep records to enable the               
          Commissioner to determine their correct tax liability.  Sec.                
          6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).               
          Deductions are a matter of legislative grace, and the taxpayer              
          bears the burden of proof to establish entitlement to any claimed           
          deduction.  Rule 142(a); New Colonial Ice Co. v. Helvering, 292             
          U.S. 435, 440 (1934).  This includes substantiation of the                  
          deductions claimed.  Hradesky v. Commissioner, 65 T.C. 87, 90               
          (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).                      
               All of the expenses at issue here, to be deductible, must              
          meet the substantiation requirements of section 274(d).  The                
          parties do not dispute that.  Section 274(d) provides generally             
          that no deduction shall be allowed for any travel expense                   
          incurred while away from home or for any item with respect to an            
          activity that is of a type generally considered to constitute               
          entertainment, amusement, or recreation, unless the taxpayer                
          substantiates by adequate records or by sufficient evidence                 
          corroborating the taxpayer's own statement (A) the amount of such           
          expense or other item, (B) the time and place of the travel,                
          entertainment, amusement, or recreation, (C) the business purpose           
          of the expense, and (D) the business relationship to the taxpayer           





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