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OPINION
On the basis of documentation petitioner provided,
respondent conceded that petitioner is entitled to many of the
disallowed Schedule C expenses. Petitioner contends that he is
entitled to additional expense deductions for fuel and expenses
related to his car, which he used to travel from his home to his
workplace, the yard where his truck was parked.
Section 162(a) allows a taxpayer to deduct "all the ordinary
and necessary expenses paid or incurred * * * in carrying on any
trade or business". Deductions are a matter of legislative
grace, and the taxpayer bears the burden of proving that he is
entitled to any deductions claimed. Rule 142(a); INDOPCO, Inc.
v. Commissioner, 503 U.S. 79, 84 (1992). Taxpayers bear the
burden of substantiating any deductions claimed. Hradesky v.
Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Taxpayers are required to maintain adequate
records sufficient to enable the Commissioner to determine their
correct tax liability. Sec. 6001; Meneguzzo v. Commissioner, 43
T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income Tax Regs.
At trial, petitioner did not provide the Court any evidence
showing his entitlement to the Schedule C expense deductions that
remain at issue. Furthermore, petitioner may not deduct the
expenses incurred in traveling between his home and his
workplace. It is well established that expenses incurred by a
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Last modified: March 27, 2008