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Petitioner contends that his wife did not receive income
during 1999. Respondent argues that petitioner’s wife had gross
income for the 1999 tax year. Respondent provided evidence in
the form of third-party information returns indicating
petitioner’s wife was the sole recipient of dividend and interest
income. Therefore, we find that petitioner is not entitled to
claim an exemption under section 151(b) for his wife.
B. Deductions
As a general rule, deductions are a matter of legislative
grace. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
It is incumbent upon a taxpayer to maintain records and
substantiate any deductions claimed. Sec. 1.6001-1(a), (e),
Income Tax Regs.
1. Donations to Goodwill and the Salvation Army
Petitioner claims he made donations to Goodwill and the
Salvation Army. Petitioner did not offer any evidence
substantiating these donations. Therefore, petitioner is not
entitled to any deductions for these claimed donations.
2. Mortgage Interest and Real Property Taxes
Petitioner’s petition appears to request a redetermination
of his tax liability taking into account itemized deductions,
mainly mortgage interest and real property taxes paid. There is
not a precise record before us regarding real property taxes and
mortgage interest.
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