- 5 - Corp. & Subs. v. Commissioner, 110 T.C. 402, 414 (1998). Deductions are a matter of legislative grace, and the taxpayer bears the burden of proving that he is entitled to any deduction claimed. Rule 142(a); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). The taxpayer is required to maintain records that are sufficient to enable the Commissioner to determine his correct tax liability. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. At trial, petitioner asserted that he incurred the following expenses in connection with driving a taxi cab: (1) $28,100 for leasing the cab; (2) $2,500 for gasoline; and (3) $1,100 for cleaning and washing the cab.2 Petitioner credibly testified that he leased a cab for an average of 4 or 5 days a week at a cost of $70 to $80 a day. Petitioner also testified that he paid for gasoline for each day he drove. Petitioner used cash to pay the lease and to purchase gasoline. Respondent disallowed the claimed expenses because of petitioner’s failure to maintain records in accordance with 2 As mentioned above, petitioner claimed $28,600 of expenses on Schedule C. This amount represents $28,100 of leasing expense and $500 of bad debt expense. A notation on Schedule C suggests that petitioner may have intended to claim the $500 as car and truck expense. In any event, petitioner offered no testimony with respect to the claimed deduction for $500, and we therefore consider that petitioner has conceded this amount of the adjustment. See Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001). Petitioner did not claim any amount for gasoline or cleaning and washing expenses on Schedule C.Page: Previous 1 2 3 4 5 6 7 8 Next
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