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Deductions are strictly a matter of legislative grace, and a
taxpayer bears the burden of proving his or her entitlement to
the claimed deductions. Rule 142(a)(1); see New Colonial Ice Co.
v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering,
supra; cf. sec. 7491(a)(2). Taxpayers are required to maintain
records sufficient to substantiate their claimed deductions. See
sec. 6001; sec. 1.6001-1(a), Income Tax Regs. This includes the
burden of substantiating the amount and purpose of the items
claimed. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. If
claimed deductions are not adequately substantiated, we may
estimate them, provided we are convinced that the taxpayer
incurred such expenses and we have a basis upon which to make an
estimate. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930);
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). Without such a
basis, any allowance would amount to unguided largesse. Williams
v. United States, 245 F.2d 559, 560 (5th Cir. 1957).
Section 217(a) provides a deduction for moving expenses paid
or incurred during the taxable year in connection with the
commencement of work by the taxpayer as an employee at a new
principal place of work.
Deductible moving expenses under section 217(a) include only
the reasonable costs: (1) Of moving a taxpayer’s household goods
and personal effects from the former residence to the new
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Last modified: May 25, 2011