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$35,910 for 1993, 1994, and 1995, respectively. Respondent
disallowed $94,268, $117,563, and $123,076 of the carryforwards
for 1993, 1994, and 1995, respectively.
A net operating loss is the excess of the deductions allowed
over the gross income. Sec. 172(c). A net operating loss for
any taxable year may be carried forward to each of the 20 taxable
years following the taxable year of the loss. Sec. 172(b).
However, deductions are strictly a matter of legislative grace.
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Taxpayers must substantiate claimed deductions. Hradesky v.
Commissioner, 65 T.C. 87, 89 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Moreover, taxpayers must keep sufficient
records to establish the amounts of the deductions. Meneguzzo v.
Commissioner, 43 T.C. 824, 831 (1965); sec. 1.6001-1(a), Income
Tax Regs.
Petitioner presented no evidence. Petitioner made no
argument that would prove he was entitled to deduct the
disallowed carryforwards. Petitioner failed to substantiate his
basis in the partnership and the amount of the net operating loss
carryover. We hold that petitioner is not entitled to deduct any
net operating loss carryover in excess of the amounts allowed by
respondent.
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