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Petitioner also claimed the following deductions and
credits:
Deduction or Credit 1999 2000
Child tax credit $1,000 $500
Credit for child and
dependent care expenses 480 ---
Charitable contribution deduction 7,447 5,202
1. Burden of Proof
A taxpayer is generally required to substantiate deductions
by keeping books and records sufficient to establish the amount
of the deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Deductions are a matter of legislative grace, and generally the
taxpayer bears the burden of proving entitlement to any deduction
claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.
79, 84 (1992). The burden of proof has not shifted to respondent
pursuant to section 7491(a). While examination of the tax
returns in issue commenced after July 22, 1998, petitioner has
not satisfied any of the criteria of section 7491(a)(2)(A) and
(B). Indeed, we found petitioner’s testimony to be questionable
or inconsistent at times.
2. Dependency Exemption Deductions
The first issue for decision is whether petitioner is
entitled to the claimed dependency exemption deductions for 1999
and 2000. Section 151(c) allows a taxpayer to deduct an
exemption amount for each dependent, as defined in section 152.
A dependent is defined as an individual, who is either a U.S.
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