Dale J. Krohn - Page 8

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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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