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Advertising $600
Car and truck 1,210
Depreciation 3,686
Insurance 243
Legal 100
Office 100
Repairs 1,500
Supplies 200
Meals and entertainment 600
Utilities 610
Petitioner did not report any revenue from the video
activity on his 1993 Federal income tax return. Respondent has
determined that petitioner failed to substantiate entitlement to
deductions for meals, repairs, depreciation, and car expenses.
Taxpayers are required to keep sufficient records to enable
respondent to determine their correct tax liability. See sec.
6001; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976). Moreover, deductions are
strictly a matter of legislative grace, and a taxpayer has the
burden of establishing that he or she is entitled to any
deduction claimed on a return. See Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992).
Under certain circumstances, where a taxpayer establishes
entitlement to a deduction but does not establish the amount of
the deduction, the Court is permitted to estimate the amount
allowable. See Cohan v. Commissioner, 39 F.2d 540 (2d Cir.
1930). However, there must be sufficient evidence in the record
to permit the Court to conclude that a deductible expense was
incurred in at least the amount allowed. See Williams v. United
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