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entirety. Respondent did not disturb the other itemized
deductions claimed by petitioner on Schedule A.4
Petitioner disputed respondent’s deficiency determination by
timely filing a petition for redetermination.
Discussion
A. General Principles
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that 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); see INDOPCO, Inc. v. Commissioner, 503 U.S. 79,
84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). 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); cf. sec. 7491(a) (which section does not serve to effect
any burden-shifting in the instant case given petitioner’s
failure (1) to raise the matter and (2) to comply with all of the
requirements of section 7491(a)(2)).
We also observe that section 6001 and the regulations
promulgated thereunder require taxpayers to maintain records
4 The allowed deductions exceeded the amount of the
standard deduction to which petitioner would otherwise have been
entitled.
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