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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.
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