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Gas & Electric Co. He reported wages of $44,799 on his 1997
Federal income tax return. Petitioner’s mother, Narvella W.
Morgan (Mrs. Morgan), suffered from various kidney and heart
ailments and required dialysis treatments and heart medications
for at least 2 years before her death in 1998. During 1997 Mrs.
Morgan received $8,820 of Social Security benefits, consisting of
$8,310 of pension for 1997 and $510 repayment for 1993. She also
received Medicare benefits, which petitioner testified were less
than $200 per month. In January 1997, petitioner moved in with
Mrs. Morgan, who previously had been living by herself. In
October 1997, petitioner married and moved out of Mrs. Morgan’s
apartment. During the year in issue, petitioner never paid any
part of Mrs. Morgan’s apartment rent of approximately $450 per
month.
On his 1997 Federal income tax return, petitioner claimed
Mrs. Morgan as a dependent. His tax return indicated that he
lived with Mrs. Morgan during all 12 months of 1997. Respondent
disallowed the claimed dependency exemption deduction.
Income tax deductions are a matter of legislative grace, and
the taxpayer bears the burden of clearly showing the right to the
claimed deduction. INDOPCO, Inc. v. Commissioner, 503 U.S. 79,
84 (1992). Taxpayers are required to maintain records sufficient
to substantiate their claimed deductions. Sec. 6001; sec.
1.6001-1(a), Income Tax Regs. Petitioner bears the burden of
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