- 6 -
on her return was excessive to the extent of $6,629.9 We proceed
to determine whether petitioner is entitled to a charitable
contribution deduction in an amount that lies somewhere in
between the parameters set by the parties, and we begin by noting
several fundamental and familiar principles of Federal income
taxation.
Deductions are a matter of legislative grace, and taxpayers
who claim deductions must establish entitlement to them.10 Rule
142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992);
New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Furthermore, a taxpayer is required to maintain records that are
sufficient to enable the Commissioner to determine the taxpayer’s
correct tax liability. See sec. 6001; sec. 1.6001-1(a), Income
Tax Regs. The taxpayer bears the burden of substantiating the
amount and purpose of the claimed deduction. See Hradesky v.
Commissioner, 65 T.C. 87 (1975), affd. per curiam 540 F.2d 821
(5th Cir. 1976).
The issues in this case arise as a result of the charitable
contribution deduction claimed on petitioner’s 2002 return.
Generally speaking, a taxpayer is allowed to deduct any
9 This amount consists of $1,160 in cash contributions and
$5,469 in property contributions.
10 Neither party suggests that sec. 7491(a) requires departure
from this general rule.
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