Stephan Bartsch and Eva Bartsch, a.k.a. Eva Pott Bartsch - Page 7

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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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