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Deductions are a matter of legislative grace, and
petitioners have the burden of proving their entitlement to them.
See, e.g., Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.
79, 84 (1992); Deputy v. Du Pont, 308 U.S. 488, 493 (1940); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Section
162(a)(2) allows a deduction for ordinary and necessary
transportation expenses made in the pursuit of a trade or
business paid or incurred during the taxable year, which may
include the cost of operating a passenger automobile to the
extent that it is used in a trade or business. See Rev. Proc.
93-51, 1993-2 C.B. 593. Taxpayers, however, must maintain
records sufficient to substantiate deductions claimed. See
Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax
Regs. A taxpayer’s cost of commuting between his residence and
his place of business or employment is a nondeductible personal
expense, while the costs associated with travel between work
assignments are deductible. See Heuer v. Commissioner, 32 T.C.
947 (1959), affd. per curiam 283 F.2d 865 (5th Cir. 1960); secs.
1.162-2(e), 1.262-1(b)(5), Income Tax Regs. Petitioners have not
contended that Dr. Hillman’s residence served as an office;
accordingly, trips between his residence and any work site are
nondeductible commuting expenses. See Sheldon v. Commissioner,
50 T.C. 24, 27 (1968).
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