- 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...)
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