-9-
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Second,
deductions are a matter of legislative grace, and the taxpayer
must show that he or she is entitled to any deduction claimed.
Rule 142(a); Deputy v. du Pont, 308 U.S. 488, 493 (1940). This
includes the burden of substantiation. Hradesky v. Commissioner,
65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976).
A taxpayer must substantiate amounts claimed as deductions
by maintaining the records necessary to establish he or she is
entitled to the deductions. Sec. 6001; Hradesky v. Commissioner,
supra. A taxpayer shall keep such permanent records or books of
account as are sufficient to establish the amount of deductions
claimed on the return. Sec. 6001; sec. 1.6001-1(a), (e), Income
Tax Regs. The Court need not accept a taxpayer’s self-serving
testimony when the taxpayer fails to present corroborative
evidence. Beam v. Commissioner, T.C. Memo. 1990-304 (citing
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986)), affd. without
published opinion 956 F.2d 1166 (9th Cir. 1992).
If a taxpayer establishes that he or she paid or incurred a
deductible business expense but does not establish the amount of
the deduction, this Court may approximate the amount of the
allowable deduction, bearing heavily against the taxpayer whose
inexactitude is of his or her own making. Cohan v. Commissioner,
39 F.2d 540, 543-544 (2d Cir. 1930). For the Cohan rule to
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