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Schedule C and the PDA consulting Schedule C.
Respondent issued to petitioner a notice of deficiency
(notice) for his taxable year 2001. In that notice, respondent
disallowed, inter alia, the $23,318 of job expenses that peti-
tioner claimed as a deduction in the 2001 Schedule A after the
reduction required by section 67(a), the $2,060 net loss that
petitioner claimed in the restaurant Schedule C, and the $15,186
net loss that petitioner claimed in the PDA consulting Schedule
C.
OPINION
Petitioner bears the burden of proving that the determina-
tions in the notice are erroneous.6 Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are a
matter of legislative grace, and petitioner bears the burden of
proving entitlement to any deduction claimed. INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992). Petitioner was required to
maintain records sufficient to establish the amount of any
deduction claimed. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Before turning to the issues presented, we shall summarize
certain principles applicable to those issues and evaluate
certain evidence on which petitioner relies.
6Petitioner does not claim that the burden of proof shifts
to respondent under sec. 7491(a). We conclude that the burden of
proof does not shift to respondent under sec. 7491(a).
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