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1996, Mr. Maher worked in the tax department of the New York
Times. When he left the New York Times in 1996, Mr. Maher was
its tax director. From 1997 through September 2001, Mr. Maher
performed financial consulting and tax work for Coopers & Lybrand
and its successor (Coopers). In 1998, he was a manager at
Coopers and worked in the Stamford, Connecticut, office. Since
September 2001, Mr. Maher has been a financial consultant and tax
return preparer for individuals.
Mr. Maher’s 1998 Tax Return
Mr. Maher received a Form W-2, Wage and Tax Statement, from
Coopers for 1998 reporting $121,145 in wages. He also received
Forms 1099-DIV and 1099-INT for 1998 reporting dividends and
interest.
Before 1998, Mr. Maher filed all of his required tax
returns. He did not file a Federal individual income tax return
for 1998. Mr. Maher knew that he was required to file a tax
return for 1998 by April 15, 1999. In 2001, he provided a copy
of an unfiled return for 1998 to respondent.
OPINION
Deductions are a matter of legislative grace, and the
taxpayer has the burden of showing that he is entitled to any
deduction claimed.3 Rule 142(a); New Colonial Ice Co. v.
3 Mr. Maher does not contend that sec. 7491(a) is
applicable to this case.
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