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license. Petitioner paid $403.95 in 1994 for expenses relating
to a Delaware corporation of which she was a shareholder.
Finally, petitioner paid interest of $481.65 and $118.19 in 1993
and 1994, respectively, on a personal loan for an automobile.
OPINION
We must decide whether petitioner (1) is entitled to any
Schedule A itemized deductions for the 1993 and 1994 taxable
years; (2) is liable for additional tax under section 72; and (3)
is liable for any additions to tax under section 6651(a) or
6654(a).
I. Schedule A Itemized Deductions
Deductions are a matter of legislative grace, and petitioner
bears the burden of proving that she is entitled to the
deductions she is claiming. See Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435 (1934). Taxpayers are required to
maintain records that are sufficient to enable the Commissioner
to determine their correct tax liability. See sec. 6001;
Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965); sec.
1.6001-1(a), Income Tax Regs. Moreover, a taxpayer who is
claiming a deduction bears the burden of substantiating the
amount and purpose of the item claimed. See Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax Regs.
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