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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