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Respondent’s determinations are presumed correct, and
petitioners bear the burden of proof. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
B. Whether Petitioners Are Entitled to More Itemized Deductions
Than Respondent Allowed for 2000 and 2001
A taxpayer must keep records that are sufficient to enable
the Commissioner to determine his or her tax liability. See sec.
6001; INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); sec.
1.6001-1(a), Income Tax Regs. A taxpayer must substantiate the
payments which give rise to claimed deductions. Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976); see sec. 6001. Petitioners have the burden
of establishing that they are entitled to the deductions claimed.
See New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Petitioners were given numerous opportunities to submit
documentation to substantiate their deductions, but they did not
do so. We have long held that where the taxpayer does not
substantiate claimed deductions, the Commissioner’s disallowance
of them will be sustained. Roberts v. Commissioner, 62 T.C. 834,
836-837 (1974); Pfluger v. Commissioner, T.C. Memo. 1986-78,
affd. 840 F.2d 1379 (7th Cir. 1988). The record in this case
provides no basis for estimating deductions under Cohan v.
Commissioner, 39 F.2d 540, 544 (2d Cir. 1930). See Lerch v.
Commissioner, 877 F.2d 624, 628-629 (7th Cir. 1989), affg. T.C.
Memo. 1987-295; Lutheran Mut. Life Ins. Co. v. United States, 816
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