- 4 - and cooperate fully with respondent’s reasonable requests. Petitioner therefore bears the burden of proof. Petitioner’s Claimed Itemized Deductions 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. Petitioner provided no information as to itemized deductions and effectively conceded the issue. Respondent is accordingly sustained on this issue, except to the extent of concessions made prior to trial. Petitioner’s assertion that she should not be liable for tax because her return preparer may have violated certain laws is misplaced. Congress has provided the Commissioner with remedies that may be enforced against dishonest return preparers. See secs. 6694, 6695, 7407; Hyler v. Commissioner, T.C. Memo. 2005-26. There is no provision in law, however, that would relieve petitioner of her personal liability for a tax deficiency on account of a dishonest return preparer. Hyler v. Commissioner, supra. We note that a taxpayer may be relieved from an accuracy-related penalty under section 6662(a) where the taxpayer reasonably relies on a return preparer. ASAT,Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007