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Substantiation of Expenses
We next examine whether petitioners are entitled to deduct
expenses for cleaning Mr. Wilbert’s uniforms. We begin by noting
the fundamental principle that the Commissioner’s determinations
are generally presumed correct, and the taxpayer bears the burden
of proving that these determinations are erroneous.7 Rule
142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992);
Welch v. Helvering, 290 U.S. 111 (1933). Moreover, deductions
are a matter of legislative grace, and the taxpayer has the
burden to prove he or she is entitled to any deduction claimed.
Rule 142(a); Deputy v. du Pont, 308 U.S. 488, 493 (1940); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v.
Helvering, supra. This includes the burden of substantiation.
Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976).
A taxpayer must substantiate amounts claimed as deductions
by maintaining the records necessary to establish he or she is
entitled to the deductions. Sec. 6001; Hradesky v. Commissioner,
supra. The taxpayer shall keep such permanent records or books
of account as are sufficient to establish the amounts of
deductions claimed on the return. Sec. 6001; sec. 1.6001-1(a),
7Petitioners do not claim the burden of proof shifted to
respondent under sec. 7491(a). Petitioners also did not
establish that they satisfy the requirements of sec. 7491(a)(2).
We therefore find that the burden of proof remains with
petitioners.
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