-5-
particular organization (the Organization), and he asks that we
allow him to audit the Organization and pay the taxes he owes out
of the proceeds of that audit, even though petitioner’s tax
liability is not related to the Organization. Petitioner has not
filed Federal income tax returns for any year after 2003, and he
does not intend to file voluntarily any returns or pay any tax
until respondent takes some action against the Organization. In
trying to resolve some of the issues in this case, petitioner has
provided summaries of his expenses for the years in issue but has
not provided any corroborating documents.
OPINION
Deductions
A taxpayer bears the burden of proving that the
Commissioner’s determinations set forth in the notice of
deficiency are incorrect. Rule 142(a)(1); Welch v. Helvering,
290 U.S. 111, 115 (1933). Tax deductions are a matter of
legislative grace, and a taxpayer has the burden of proving that
he is entitled to the deductions claimed. Rule 142(a)(1);
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). In
addition, a taxpayer must keep sufficient records to substantiate
any deductions claimed. Sec. 6001; New Colonial Ice. Co. v.
Helvering, supra at 440. Section 7491(a) does not apply in this
case because petitioner has not substantiated the deductions he
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