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In determining the taxable income reported in petitioner’s
2002 tax return, petitioner deducted $257 as medical and/or
dental expenses and $16,874 as job expenses, as well as the other
itemized deductions claimed in the 2002 Schedule A, including the
claimed $980 of charitable contributions, that were not subject
to the 7.5-percent floor imposed by section 213(a) or the two-
percent floor imposed by section 67(a).
Respondent issued to petitioner a notice of deficiency
(notice) for his taxable year 2002. In that notice, respondent
disallowed the deductions for the $257 of medical and/or dental
expenses that petitioner claimed in the 2002 Schedule A after the
reduction required by section 213(a), the $980 of charitable
contributions that petitioner claimed in the 2002 Schedule A, and
the $16,874 of job expenses that petitioner claimed in the 2002
Schedule A after the reduction required by section 67(a).
Discussion
Petitioner bears the burden of proving that the determina-
tions in the notice are erroneous.2 Rule 142(a); Welch v.
Helvering, 290 U.S. 111 (1933). Moreover, deductions are a
matter of legislative grace, and the taxpayer bears the burden of
proving entitlement to any deduction claimed. INDOPCO, Inc. v.
2Petitioner does not claim that the burden of proof shifts
to respondent under sec. 7491(a). In any event, petitioner has
failed to establish that he satisfies the requirements of sec.
7491(a)(2). On the record before us, we find that the burden of
proof does not shift to respondent under sec. 7491(a).
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