Steve J. Work - Page 7

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          II. Substantiation of Deductions                                            
               Taxpayers are required to maintain records that are                    
          sufficient to enable the Commissioner to determine their correct            
          tax liability.  See sec. 6001; sec. 1.6001-1(a), Income Tax Regs.           
          In addition, the taxpayer bears the burden of substantiating the            
          amount and purpose of the item for the claimed deduction.  See              
          Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam           
          540 F.2d 821 (5th Cir. 1976).                                               
               A.  1998 (Moving Expenses)                                             
               Section 217(a) allows a deduction for moving expenses paid             
          or incurred during the taxable year in connection with the                  
          commencement of work by the taxpayer as an employee or as a self-           
          employed individual at a new principal place of work.  Respondent           
          concedes that petitioner satisfied the conditions for allowance             
          imposed by section 217(c).  Section 217(b)(1) provides, in                  
          relevant part:                                                              
               the term “moving expenses” means only the reasonable                   
               expenses--                                                             
                         (A) of moving household goods and personal                   
                    effects from the former residence to the new                      
                    residence, and                                                    
                         (B) of traveling (including lodging) from the                
                    former residence to the new place of residence.                   
          Section 217(b) was amended to read as above by the Omnibus Budget           
          Reconciliation Act of 1993 (OBRA), Pub. L. 103-66, sec.                     
          13213(a)(1), 107 Stat. 473.  The amendments made by OBRA section            






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