Terry and Kathryn A. Roditski Dilozir - Page 2

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          petitioners' 1993 Federal income tax in the amount of $3,538 and            
          an accuracy-related penalty under section 6662(a) in the amount             
          of $708.  The issues for decision are:  (1) Whether petitioners             
          are entitled to deduct certain claimed Schedule C expenses; (2)             
          whether petitioners underreported capital gain income on Schedule           
          D by the amount of $22,116; and (3) whether petitioners are                 
          liable for the accuracy-related penalty under section 6662(a).              
               For clarity and convenience, we have combined the findings             
          of fact and discussion of pertinent legal issues.  Some of the              
          facts have been stipulated and are so found.  The stipulation of            
          facts and the attached exhibits are incorporated herein by this             
          reference.  Petitioners resided in Avon, Connecticut, at the time           
          the petition was filed.                                                     
               We begin by noting that petitioners bear the burden of                 
          proving that respondent's determination is erroneous.  Rule                 
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).  Moreover,            
          deductions are a matter of legislative grace, and petitioners               
          bear the burden of proving that they are entitled to any                    
          deductions claimed.  INDOPCO, Inc. v. Commissioner, 503 U.S. 79,            
          84 (1992).                                                                  
          1. Schedule C Deductions                                                    
               Petitioner Terry Dilozir (petitioner) was self-employed as a           
          real estate agent during the year in issue.  Petitioner worked in           

               1(...continued)                                                        
          Procedure.                                                                  




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