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table in this area which petitioner does not clear off for eating
his meals. In his apartment, petitioner has three televisions,
which he watches for recreation.
In the notice of deficiency respondent made the following
adjustments to Schedule C deductions by petitioner:
1996
Claimed Allowed Disallowed
Car and truck $4,900 $1,225 $3,675
Interest 250 0 250
Travel 2,864 1,682 1,182
Utilities 120 26 94
Exhibits 575 550 25
General 1,949 683 1,266
Association 225 227 (2)
fees
Business use of 4,130 826 3,304
home
Total $15,013 $5,219 $9,794
All numbers are rounded up to the nearest dollar.
Respondent disallowed deductions in the amounts shown above
because petitioner failed to show that each claimed deduction was
an ordinary and necessary business expense, or, in the
alternative, because petitioner failed to substantiate the
claimed deduction.
Discussion
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving the entitlement to any
deduction claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79,
84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). A taxpayer is required to maintain records sufficient to
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