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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), the
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