- 7 - conceded that the additions to tax for his 1999 taxable year under sections 6651(a)(1) and 6654 apply to any underpayment finally decided by the Court. Itemized and Schedule C Deductions In his petition, petitioner contends that respondent’s adjustments for itemized deductions are incorrect and that petitioner is entitled to the full amount of deductions claimed. Prior to trial, respondent allowed the following itemized deductions: Itemized Deductions Amount Medical and dental $7,326 State and local taxes 1,935 Real estate taxes 3,119 Other taxes 1,783 Home mortgage interest 22,481 Charitable contributions 15,900 Miscellaneous deductions subject to the 2% AGI limitation 13,765 Total $66,309 Petitioner was able to provide substantiation for the above amounts but did not show entitlement to amounts in excess of the those allowed by respondent. Tax deductions are a matter of legislative grace with a taxpayer bearing the burden of proving entitlement to the deductions claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Rule 142(a)(1). A taxpayer bears the burden of substantiating the amount and purpose of any claimed deduction.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011