-7-
are erroneous. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503
U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Moreover, deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that he or she is entitled
to any deduction claimed. Rule 142(a); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, supra.
This includes the burden of substantiation. Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976); see also sec. 6001 and sec. 1.6001-1(a),
(e), Income Tax Regs., (requiring taxpayers to maintain
sufficient records to permit verification of deductible
expenses).
1. Automobile-related Expenses
Petitioners claimed deductions for "Car & Truck" in the
amount of $1,972 and for "Rent, vehicles" in the amount of
$1,525. Respondent allowed $98 of the deduction claimed for "Car
& Truck" and disallowed the balance of that deduction.
Respondent disallowed the deduction claimed for "Rent, vehicles"
in its entirety.
Petitioner contends that he used an automobile to commute to
and from work, to travel between the Red Lion and SeaTac Airport,
and to purchase supplies. In this regard, petitioner contends
that the deduction claimed for "Car & Truck" represents the cost
of operating the automobile, and that the deduction claimed for
"Rent, vehicles" represents the cost of leasing the automobile.
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