- 7 -
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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