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not employed outside the home. Petitioners also had an oil/gas
operating interest.
Respondent contends that petitioners did not provide
adequate substantiation for the disallowed items. Petitioner
presented numerous receipts into evidence. Petitioner also tried
to submit evidence at trial, which we excluded as it was not
presented to respondent within 15 days of trial as required by
our Standing Pre-Trial Order. Schaefer v. Commissioner, T.C.
Memo. 1998-163, affd. in unpublished opinion 188 F.3d 514 (9th
Cir. 1999).
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. Generally, except as otherwise provided by section
274(d), when evidence shows that a taxpayer incurred a deductible
expense, but the exact amount cannot be determined, the Court may
approximate the amount bearing heavily if it chooses against the
taxpayer whose inexactitude is of his own making. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The Court,
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