- 41 - because petitioners did not: (1) Adequately substantiate those deductions; and/or (2) establish the business purpose for the deductions. We begin with a fundamental proposition of Federal income taxation. Deductions are matters of legislative grace. New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Segel v. Commissioner, 89 T.C. 816, 842 (1987). Taxpayers are required to substantiate the claimed deductions by maintaining records necessary to establish entitlement and the amount of the deduction in question. Sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income Tax Regs.; see Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933); Segel v. Commissioner, supra; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). In general, the burden to demonstrate entitlement to a claimed deduction rests with the taxpayer. Rule 142(a); Underwood v. Commissioner, 56 F.2d 67 (4th Cir. 1932), revg. 20 B.T.A. 1117 (1930). Generally, section 162(a) allows “as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business”, including a taxpayer’s trade or business as an employee. See Primuth v. Commissioner, 54 T.C. 374, 377-378 (1970). To support expensesPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: November 10, 2007