8 that petitioner conceded this issue up until the day of trial, and then sought to withdraw his concession. The determinations of respondent are presumed to be correct, and petitioners bear the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933). All taxpayers are required to keep sufficient records to enable the Commissioner to determine their correct tax liability. Sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965). Petitioners offered no evidence to show that respondent's determination was incorrect. We conclude that petitioner failed to report taxable income from CSRS in the amount of $464. Respondent is sustained on this issue. Issue 4. DOA Distribution Prior to trial, petitioner stipulated that he received and failed to report $580 of taxable income from DOA. At trial, petitioner attempted to withdraw his stipulation and argued that the $580 represents moneys borrowed from DOA which he repaid through payroll deductions. In support of his argument, petitioner presented an Earnings, Leave and Benefit Statement issued on July 12, 1990, by DOA, indicating that $79.10 had been withheld from his wages during 1990 for repayment of a thrift savings plan loan. Petitioner offered no documentation to prove that the $580 reported by DOA to the Internal Revenue Service as taxable incomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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