David G. Turner - Page 10

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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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