- 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,Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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