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expense deductions for Mr. Booker’s business. Respondent
disallowed the claimed deductions for lack of substantiation.
Petitioners also untimely filed their 2000 Federal income
tax return on June 7, 2001. On that return, petitioners claimed
a dependency exemption deduction for Mrs. Booker’s mother.
Petitioners also claimed itemized deductions of $13,405 for
charitable contributions and $19,998 for various trade or
business expenses deductions in connection with Mr. Booker’s
business. Respondent also disallowed these deductions for lack
of substantiation.
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving entitlement to any
deductions claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner,
503 U.S. 79, 84 (1992). The taxpayer is required to identify
each deduction available and show that all requirements have been
met. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). It is also the taxpayer’s responsibility to maintain
records sufficient to enable the Commissioner to determine the
correct tax liability. Sec. 6001; Higbee v. Commissioner, 116
T.C. 438 (2001); sec. 1.6001-1(a), Income Tax Regs. The taxpayer
must substantiate both the amount and purpose of claimed
deductions. Higbee v. Commissioner, supra. As previously
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