Thu Cuc Thi Huynh - Page 17




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          his position.  Maggie Mgmt. Co. v. Commissioner, supra at 442               
          (citing Huffman v. Commissioner, 978 F.2d 1139, 1144-1147 (9th              
          Cir. 1992), affg. in part and revg. in part on another ground               
          T.C. Memo. 1991-144).  In the present case, however, we need not            
          follow this approach because respondent’s position was                      
          essentially the same in the administrative and litigation                   
          proceedings.  See Maggie Mgmt. Co. v. Commissioner, supra at 442.           
          More specifically, respondent’s position was that petitioner had            
          failed to substantiate her entitlement to head of household                 
          filing status (and the standard deduction for that filing status)           
          and a dependency exemption deduction and earned income credit in            
          respect of her son.                                                         
               Deductions and credits are matters of legislative grace.               
          New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934);                
          Segel v. Commissioner, 89 T.C. 816, 842 (1987).  The same may be            
          said of a tax-favored filing status such as head of household.              
          See D’Anjou v. Commissioner, T.C. Memo. 1992-138.  Taxpayers are            
          required to substantiate the deductions and credits that they               
          claim by maintaining records necessary to establish both the                
          taxpayers’ entitlement to such items and the proper amount                  
          thereof.  Sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-           
          832 (1965); sec. 1.6001-1(a), Income Tax Regs.; see Rule 142(a);            
          INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v.             
          Helvering, 290 U.S. 111, 115 (1933); Segel v. Commissioner,                 






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