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also claimed a mortgage interest deduction of $9,303 and a
property tax deduction of $1,532.
In notices of deficiency, respondent determined Gabriel was
not entitled to dependency exemption deductions for Mahmoud and to
head of household filing status for tax years 1995 and 1996.
Respondent further determined Gabriel was not entitled to
deductions for home mortgage interest expense and for property tax
expense in 1995. Respondent disallowed all but 5 percent of
Gabriel’s deductions for home mortgage interest expense and for
property tax expense in 1996. As a result of respondent’s
adjustments, Gabriel’s itemized deductions for each of the years
in issue were reduced to amounts less than the allowable standard
deduction. Gabriel’s tax liability, therefore, was determined
using the standard deduction for each of the years in issue.
Respondent determined Morhaf was not entitled to head of
household filing status and to deductions for mortgage interest
expense and property tax expense in taxable year 1995.
Respondent’s determination reduced Morhaf’s itemized deductions to
an amount less than the standard deduction in 1995; thus, Morhaf’s
tax liability was determined using the standard deduction.
OPINION
Deductions are strictly a matter of legislative grace, and
taxpayers must satisfy the specific requirements for any deduction
claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84
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