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B. Petitioner’s Income in 2000 and 2002
1. Respondent’s Determination
Petitioner has not shown that respondent’s determination
relating to the amount of his income for 2000 and 2002 is
incorrect. We conclude that petitioner received taxable income
in 2000 and 2002 as determined by respondent.
2. Increased Deficiency for 2000
As discussed above, the Commissioner has the burden of
proving increased deficiencies and additions to tax asserted in
the pleadings. Rule 142(a). Petitioner received dividends of
$830.31 in 2000 that respondent did not determine to be included
in petitioner’s income for 2000. Thus, respondent has proven the
increased deficiency for 2000. We conclude that petitioner
received income as described above in the findings of fact.
C. Petitioner’s Deductions
A taxpayer must keep records that are sufficient to enable
the Commissioner to determine his or her tax liability. Sec.
6001; sec. 1.6001-1(a), Income Tax Regs. Deductions are a matter
of legislative grace. INDOPCO, Inc. v. Commissioner, 503 U.S.
79, 84 (1992). 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.
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