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business. Petitioner therefore may deduct the amount of MBA
tuition expenses that he substantiated.15
C. Whether Petitioner Adequately Substantiated Tax Preparation
Fees and Unreimbursed Employee Business Expenses
We next address whether petitioner may deduct non-education
expenses and tax preparation fees. Taxpayers do not have an
inherent right to take deductions. Deductions are a matter of
legislative grace, and taxpayers must establish their right to
take them. Deputy v. du Pont, 308 U.S. 488, 493 (1940); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Taxpayers must substantiate any deductions and bear the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 89-90
(1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).
In addition to the substantiation requirements for ordinary
and necessary business expenses, taxpayers are subject to more
stringent substantiation requirements for certain expenses. See
secs. 162(a), 274(d). For instance, taxpayers must strictly
substantiate the nature and amount of the meal, travel, and
vehicle expenses. See sec. 274(d). For these expenses, a
taxpayer must maintain adequate records or produce sufficient
evidence to corroborate his or her statements to substantiate the
15Our finding pertains only to $15,745 in tuition-related
expenses and not $231 in parking fees petitioner associates with
his education, which he failed to substantiate. Petitioner
originally deducted $17,500 in tuition expenses, which respondent
later reduced to $15,745, without objection.
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