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Deductions are a matter of legislative grace, and petitioner
bears the burden of proving that he is entitled to the deductions
claimed. Rule 142(a); New Colonial Ice Co. v. Helvering, 292
U.S. at 440. Ordinarily, a taxpayer is permitted to deduct the
ordinary and necessary expenses that he pays or incurs during the
taxable year in carrying on a trade or business. Sec. 162(a). A
taxpayer, however, is required to maintain records sufficient to
establish the amounts of his deductions. Sec. 6001; sec. 1.6001-
1(a), Income Tax Regs.
Petitioner conceded that some expenses paid from his
business bank account were not for business purposes. Petitioner
presented no evidence to establish the business purpose of this
payment. Accordingly, we hold that petitioner is not allowed to
deduct the payment to Consolidated Electrical Distributors in
1995.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not herein
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be
entered under Rule 155.
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