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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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Last modified: May 25, 2011