David J. Boyd - Page 7

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          than Schedule A.  Petitioner was allowed the standard deduction             
          under section 63(c) instead of the claimed itemized deductions.             
          Petitioner’s Schedule C expenses as reported on the original                
          return were adjusted to allow $50 for meals, $1,500 for car and             
          truck expenses (calculated by multiplying the standard mileage              
          rate by 5,000 miles), $100 for travel expenses, $756 for                    
          memberships, and $500 for parking.  Respondent disallowed all of            
          petitioner’s charitable contributions.  The remainder of                    
          petitioner’s Schedule C expenses was not adjusted.  Respondent              
          determined $1,713 for self-employment tax and allowed a                     
          corresponding deduction for one-half of that tax.  Respondent               
          also determined the addition to tax under section 6651(a)(1).               
               Deductions are a matter of legislative grace, and the                  
          taxpayer bears the burden of proving entitlement to any                     
          deductions claimed.  Rule 142(a); INDOPCO, Inc. v. Commissioner,            
          503 U.S. 79, 84 (1992).  The taxpayer is required to identify               
          each deduction available and show that all requirements have been           
          met.  New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                  
          (1934).  It is also the taxpayer’s responsibility to maintain               
          records sufficient to enable the Commissioner to determine the              
          correct tax liability.  Sec. 6001; sec. 1.6001-1(a), Income Tax             
          Regs.; Higbee v. Commissioner, 116 T.C. 438 (2001).  The taxpayer           
          must substantiate both the amount and purpose of claimed                    
          deductions.  Higbee v. Commissioner, supra.  Moreover, the burden           





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