- 4 - Individual Income Tax Return. This form served to extend by 4 months the time within which petitioner was obliged to file his 1998 income tax return. B. Examination of Petitioner’s 1998 Income Tax Return In due course, petitioner’s 1998 income tax return was selected for examination. The focus of the examination was the deductions claimed by petitioner on his Schedule C. However, petitioner “declined to open [his] books and records” or otherwise provide substantiation for any of the deductions in question. Thereafter, respondent disallowed petitioner’s Schedule C deductions for lack of substantiation. Respondent also determined that petitioner failed to timely file his 1998 return. Discussion A. Petitioner’s Schedule C Deductions We begin with several fundamental principles that serve to guide the decisional process. First, deductions are a matter of legislative grace. Deputy v. duPont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Second, a taxpayer bears the burden of proving that the taxpayer is entitled to any deduction claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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