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organizations. The New Hope Baptist Church did not keep records
of contributions before 1994, nor did the other churches maintain
any tracking systems of contributions during the years at issue.
Petitioners did not maintain records of all their contributions.
Petitioners deducted charitable contributions of $7,953 and
$7,640 in 1992 and 1993, respectively. Respondent allowed $1,075
and $3,725 in 1992 and 1993, respectively, after petitioners
substantiated those amounts.
OPINION
All disputed items on petitioners' income tax returns are
deductions they claimed. Deductions are strictly a matter of
legislative grace, and petitioners bear the burden of proving
entitlement to any deduction claimed. Rule 142(a); INDOPCO, Inc.
v. Commissioner, 503 U.S. 79, 84 (1992).
Education Expenses
Section 162(a) allows a deduction for all ordinary and
necessary expenses incurred in carrying on a trade or business.
Education expenses are considered ordinary and necessary business
expenses if the education maintains or improves skills required
by the taxpayer in his employment or meets the express
requirements of an employer imposed as a condition for the
taxpayer's continued employment, status, or rate of compensation.
Sec. 1.162-5(a), Income Tax Regs. Education expenses, however,
are not deductible if they are "made by an individual for
education which is part of a program of study being pursued by
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