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See Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976).5 A taxpayer is required to
maintain sufficient records to establish the amounts of income
and deductions. Sec. 6001; Higbee v. Commissioner, 116 T.C. 438,
440 (2001); sec. 1.6001-1(a), Income Tax Regs. Therefore,
petitioner must produce evidence that he is entitled to
deductions in excess of what he has thus far been able to
substantiate.
At trial, petitioner did not offer evidence supporting his
claim for the above-described itemized deductions in excess of
those allowed or agreed to by respondent. See Hradesky v.
Commissioner, supra. Because petitioner has failed to provide
any substantiation to support such itemized deductions in excess
of those allowed, we sustain respondent’s position with respect
to those itemized deductions.
Petitioner further contends that he is entitled to increased
deductions with regard to his vehicle expenses claimed as a
business deduction on Schedule C of his 1999 return. At trial,
petitioner substantiated by means of documentary evidence amounts
in excess of those previously claimed for vehicle expenses. On
his 1999 return, petitioner claimed $3,915 for employee business
vehicle expense and $2,194 for his wife’s car and truck expenses.
5 No question has been raised with respect to the burden of
proof or production under sec. 7491(a).
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