- 8 - B. Petitioner’s Income in 2001 Petitioner has not shown that respondent’s determination relating to the amount of his income for 2001 is incorrect. We conclude that petitioner received income as described 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. Petitioner alleged in the petition that he is entitled to claim deductions. However, petitioner has not identified the items that he contends are deductible or offered any evidence supporting his claim. Thus, he may not deduct any amount for 2001. We conclude that petitioner’s deficiency in income tax for 2001 was $4,695. D. Additions to Tax Section 7491(c) places on the Commissioner the burden of producing evidence that it is appropriate to impose additions to tax. To meet the burden of production under section 7491(c), thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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