- 17 -
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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