- 8 - as of that date. Therefore, we find that the statute of limitations period expired on April 18, 2000. We hold that the statute of limitations does not bar assessment of the deficiency determined in the statutory notice sent to petitioner on December 28, 1999. We now address the remaining issues. Respondent disallowed the deduction of $36,167 of Schedule C expenses. Petitioner presented no testimony or other evidence regarding these deductions. 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). Section 7491(a) does not change the burden of proof where petitioner has failed to substantiate her deductions. Higbee v. Commissioner, 116 T.C. 438 (2001). 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. Because petitioner presented no substantiation, we sustain respondent's determination as to the disallowance of the deduction of $36,167 of Schedule C expenses. Under section 7491(c), respondent has the burden of production in any court proceeding with respect to the liabilityPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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