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deductions and allowed Mr. Cotton the standard deduction for 1994
and 1995. Respondent disallowed the standard deduction for Mrs.
Cotton in 1996 because Mr. Cotton itemized deductions on his
separate return.
OPINION
Deductions are a matter of legislative grace, and taxpayers
must comply with the specific requirements for any deduction
claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84
(1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). Taxpayers must maintain adequate records to substantiate
the amount of credits and deductions claimed. See sec. 6001;
sec. 1.6001-1(a), Income Tax Regs.
1. Dependency Exemption Deductions
A taxpayer is permitted to claim a deduction for personal
exemptions. See sec. 151(a). A taxpayer may claim an exemption
for dependents. See sec. 151(c)(1). A taxpayer’s son, sister,
brother, sister-in-law, brother-in-law, niece, and nephew qualify
as dependents so long as the taxpayer provided more than half of
the support to each dependent. See sec. 152(a)(1), (3), (6),
(8); sec. 1.152-1(a)(1), Income Tax Regs. Further, a taxpayer
may claim a dependency exemption deduction for an unrelated
individual who has as his principal place of abode the home of
the taxpayer, so long as the taxpayer provided more than one-half
of the support to the unrelated individual. See sec. 152(a)(9).
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