- 7 - petitioner for $836,540. Petitioner also testified that she had balance sheets for Topaz. Petitioner did not submit any documents related to the calculation of her Topaz stock basis. Petitioner has not provided evidence sufficient to establish her Topaz stock basis. Therefore, petitioner has not established that she is entitled to deduct the carryover loss on her 2000 Federal income tax return. C. Itemized Deductions Petitioner argues that she is entitled to deductions for State income taxes and unreimbursed employee expenses. Deductions are a matter of legislative grace, and petitioner bears the burden of proving that she is entitled to the deductions claimed. See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435 (1934). Taxpayers are required to maintain records that are sufficient to enable the Commissioner to determine their correct tax liability. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. In addition, the taxpayer bears the burden of substantiating the amount and purpose of the item for the claimed deduction. See Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). 1. State Income Taxes Petitioner claimed a $15,749 deduction for State income taxes paid during 2000. Section 164(a)(3) provides, inter alia,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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