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substantiate his claims.
Discussion
Deductions are a matter of legislative grace, and taxpayers
must maintain adequate records to substantiate the amounts of any
deductions or credits claimed. Sec. 6001; INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); sec. 1.6001-1(a), Income
Tax Regs. Taxpayers generally bear the burden of proving that
the Commissioner’s determinations are incorrect. Rule 142(a);
Welch v. Helvering, 290 U.S. 111 (1933). Section 7491 does not
apply because petitioner has failed to substantiate his
deductions and provide credible evidence.
1. Dependency Exemption Deductions
Section 151(c) allows a taxpayer to deduct an exemption
amount for each “dependent” as defined in section 152. As
relevant here, section 152(a) defines a dependent to include a
son or daughter of the taxpayer “over half of whose support, for
the calendar year in which the taxable year of the taxpayer
begins, was received from the taxpayer (or is treated under
subsection (c) or (e) as received from the taxpayer)”.
To qualify for a dependency exemption deduction, a taxpayer
must establish the total support cost expended on behalf of a
claimed dependent from all sources for the year and demonstrate
that he provided over half of this amount. See Archer v.
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Last modified: May 25, 2011