- 3 -
On Schedule A filed with his 1993 Federal income tax return,
petitioner claimed the following as unreimbursed employee
business expenses:
Expense Amount
Vehicle $6,351
Parking 780
Travel 5,892
Business 6,986
Meals and entertainment1 5,594
Total 25,603
1 After the 20 percent reduction. See sec. 274(n).
Respondent disallowed the claimed expenses for failure to
substantiate. Petitioner alleges that his records were destroyed
in November 1996 due to a rainstorm which flooded his apartment.
Petitioner recently found copies of the calendar in storage.
Deductions are a matter of legislative grace. See INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934). A taxpayer must
substantiate any deductions claimed and bear the burden of
substantiation. See Hradesky v. Commissioner, 65 T.C. 87, 89-90
(1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). Taxpayers
are required to maintain adequate records sufficient to establish
the amounts of the deductions. See sec. 6001; Meneguzzo v.
Commissioner, 43 T.C. 824, 831-832 (1965).
Section 162(a) allows a taxpayer to deduct all ordinary and
necessary business expenses paid or incurred during the taxable
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