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the relief of pain. Petitioner reported $580 of gross receipts
from this activity on Schedule C, Profit or Loss From Business,
and claimed $174 as the cost of goods sold and $5,167 of
business-related expenses.
OPINION
Respondent determined that petitioner was not entitled to
the deductions he claimed on his return because petitioner did
not provide any substantiation for the amounts reported.
Petitioner asserts that he is entitled to the claimed deductions;
however, he offered no books or records to prove that he actually
expended the amounts at issue.
Respondent's determinations are presumed correct, and
petitioner bears the burden of proving otherwise. See Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Taxpayers
do not have an inherent right to take tax deductions. Deductions
are a matter of legislative grace, and a taxpayer bears the
burden of proving entitlement to any deduction claimed. See
Deputy v. du Pont, 308 U.S. 488, 493 (1940); New Colonial Ice Co.
v. Helvering, 292 U.S. 435, 440 (1934). Moreover, a taxpayer is
required to maintain records that are sufficient to substantiate
his deductions. See sec. 6001.
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