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taxpayer. See Huynh v. Commissioner, T.C. Memo. 2002-110;
Gealer v. Commissioner, T.C. Memo. 2001-180; O’Bryon v.
Commissioner, supra; Cooper v. Commissioner, T.C. Memo. 1999-6.
What constitutes adequate substantiation for challenged
deductions, of course, is fertile ground for disputes between a
taxpayer and respondent, and we recognize that the nature and
quantum of substantiation for a given deduction can vary with
the circumstances. Welch v. Helvering, supra. Guidance
published by respondent identifies generally how a deduction may
be substantiated, but notes that proof that an expenditure was
made or incurred does not necessarily establish that a taxpayer
is entitled to a deduction for that expenditure. Taxpayers are
advised to keep any other documents that may prove entitlement to
the deduction. See Rev. Proc. 92-71, 1992-2 C.B. 437.
Furthermore, a taxpayer’s self-serving declaration is generally
not a sufficient substitute for records. See Weiss v.
Commissioner, T.C. Memo. 1999-17.
Respondent’s position with respect to the disallowance of
deductions claimed on petitioners’ returns flows from the
examination of those returns, and it is clear that a taxpayer’s
return is hardly substantiation for items reported on that
return. See Seaboard Commercial Corp. v. Commissioner, 28 T.C.
1034, 1051 (1957); Halle v. Commissioner, 7 T.C. 245, 247 (1946),
affd. 175 F.2d 500 (2d Cir. 1949).
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