Robert Walter Allison - Page 5




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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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