- 9 - question." Simpson Financial Services, Inc. v. Commissioner, T.C. Memo. 1996-317. We have stated on many occasions that deductions are strictly a matter of legislative grace. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers must substantiate any deductions claimed through sufficient records. Sec. 6001; Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). Respondent's position was based on the examination of petitioner's return. In the notice of deficiency issued to petitioner following the examination, respondent allowed $5,919 of the claimed $23,276 in deductions. The difference of $17,357 was disallowed because of petitioner's failure to substantiate the remaining items on her return. This was only a substantiation case. Although petitioner repeatedly stated in her petition that she had additional documents or adequate evidence to substantiate the claimed deductions, there is no evidence in the record that suggests that the necessary documents were available to respondent until approximately 7 months after respondent filed the answer. Prior to the issuance of the notice of deficiency, petitioner admitted in her August 21, 1996 letter to respondent that "most of my original expenditure documents have been misplaced or destroyed * * * . Therefore, I must rely on your reasonable judgment by extrapolating from documents enclosed and professionalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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