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language and purpose of recordkeeping for contributions in excess
of $250. We find that petitioner is not entitled to a charitable
contribution deduction.
Education Loan Interest Deduction Under Section 221
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving the entitlement to any
deduction claimed. See Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992). A taxpayer is required to
maintain records sufficient to establish the amount of his or her
income and deductions. Sec. 6001; sec. 1.6001-1(a), (e), Income
Tax Regs.
Section 221(a) provides that a deduction is allowed for an
amount equal “to the interest paid by the taxpayer * * * on any
qualified education loan.” Section 221(d) defines a “qualified
education loan” as “any indebtedness incurred by the taxpayer
solely to pay qualified higher education expenses”.
The only documentary evidence concerning the alleged
educational loan is a letter from the Cooperative Rabobank West-
Zeeuws-Vlaanderen U.A. addressed to P.A.E.L. Weyts (we assume
petitioner) in Brugge, Belgium, stating that the interest paid on
the “mortgage loan” in 2000 was EURO 6,197.28 and that the
balance of the loan as of January 1, 2001, was EURO 123,946.28.
The record does not include the loan agreement or any documentary
evidence of when and how, if at all, petitioner paid the
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