- 17 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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