Christopher D. and Kristie M. Farran - Page 12

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          the taxpayer bears the burden of proving that these                         
          determinations are erroneous.6  Rule 142(a); INDOPCO, Inc. v.               
          Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290               
          U.S. 111 (1933).  Moreover, deductions are a matter of                      
          legislative grace, and the taxpayer has the burden to prove he or           
          she is entitled to any deduction claimed.  Rule 142(a); Deputy v.           
          du Pont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v.                  
          Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, supra.             
          This includes the burden of substantiation.  Hradesky v.                    
          Commissioner, 65 T.C. 87, 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.  The taxpayer shall keep such permanent records or books             
          of account as are sufficient to establish the amounts 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-             

               6Petitioners do not claim the burden of proof shifts to                
          respondent under sec. 7491(a).  Petitioners also did not                    
          establish they satisfy the requirements of sec. 7491(a)(2).  We             
          therefore find that the burden of proof remains with petitioners.           

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