James E. Copley and Cynthia R. Copley - Page 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 income           

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