- 16 - supra. Accordingly, because petitioner’s MAGI plus one-half of his benefits exceeds the adjusted base amount, a portion of his Social Security benefits is taxable. See sec. 86(a)(2), (c)(2). Thus, we sustain respondent’s determination on this issue. C. Petitioner’s IRA Deductions As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the burden of proving his or her entitlement to the claimed deductions.18 Rule 142(a)(1); see New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933); cf. sec. 7491(a)(2). Taxpayers are required to maintain records sufficient to substantiate their claimed deductions. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. Generally, a taxpayer is entitled to a deduction for qualified retirement contributions. Sec. 219(a); sec. 1.219- 1(a), Income Tax Regs. As relevant herein, section 219(e) defines a qualified retirement contribution as “any amount paid in cash for the taxable year by or on behalf of an individual to an individual retirement plan for such individual’s benefit.”19 18 Because petitioner has not established that he fully complied with the substantiation requirements of sec. 7491(a)(2)(A), we decide the issue before us without regard to sec. 7491(a)(1). 19 Sec. 7701(a)(37) defines an individual retirement plan as an individual retirement account described in sec. 408(a) and (continued...)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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