-11- 2003. It was deemed admitted under Rule 37(c) that petitioner received income in the amount of $95,382, incurring an income tax liability of $23,585 for 2003.13 We therefore hold that petitioner received unreported income in the above amount. B. Disallowed Deductions In addition to the receipt of unreported income, respondent determined that petitioner overstated deductions. Section 161 provides for itemized deductions in computing taxable income. However, deductions are a matter of legislative grace, and a taxpayer bears the burden of proving that he has complied with the specific requirements for any deduction he claims. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). The taxpayer has the burden of substantiating any deduction. Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976); see also Rule 142(a). Respondent denied or reduced petitioner’s claimed deductions for the years 2000, 2001 and 2002, including a Schedule E expense for 2001. Petitioner presented no evidence to substantiate any of these deductions. Furthermore, at trial petitioner refused to answer questions about his deductions for the years at issue, asserting meritless arguments. Therefore, petitioner has failed to meet his burden with respect to the disallowed deductions. 13Respondent allowed petitioner certain itemized deductions totaling $13,142.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007