James W. Taylor - Page 7




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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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