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such as receipts or bills. See sec. 1.274-5(c)(2), Income Tax
Regs. In combination, these records must be sufficient to
establish each element--amount, time and place, business purpose,
and business relationship–-of the expenditure for which a
deduction is sought.
In the absence of adequate records to substantiate each
element of an expense under section 274, a taxpayer may
alternatively establish such element: (A) By his own statement,
whether written or oral, containing specific information in
detail as to such element; and (B) by other corroborative
evidence sufficient to establish such element. See sec. 1.274-
5(c)(3), Income Tax Regs.
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of establishing entitlement to any
claimed deduction. See Rule 142(a); see also INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934); Hradesky v. Commissioner, 65
T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976). The taxpayer is required to maintain records sufficient
to establish the amount of his income and deductions. See sec.
6001; sec. 1.6000-1(a), (e), Income Tax Regs.
For the most part, the business records that petitioner
relies upon to establish his claimed deductions do not reflect
the sort of systematic record keeping that one might expect of a
practicing C.P.A. Rather, they more closely resemble the
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