- 4 - the rest of the accounting records that he was relying on and to provide them to respondent. Because petitioner’s records were discovered, during trial, to be fraught with errors, the Court concluded that respondent was prejudiced by petitioner’s violation of the pretrial order. The Court therefore sustained respondent’s objection to the admission of those documents into evidence. However, the record was held open until July, 9, 2007, to offer petitioner an opportunity to confer with respondent in order to reach an agreement concerning the filing of additional documents. Such documents could have included corrected versions of the documents that were not admitted into evidence at trial and additional supplemental stipulations of the parties. Petitioner failed to confer with respondent and then inexplicably failed to file a brief or a reply brief. In the end, although provided ample opportunity, petitioner has done little to help himself prevail on the remaining issues. OPINION I. General Deduction Rules Deductions are a matter of legislative grace, and the taxpayer must maintain adequate records to substantiate the amounts of any deductions or credits claimed. Sec. 6001; INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); sec. 1.6001-1(a), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008