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As of the date of the trial herein, a Mark IV helmet was
being offered for sale for $800 by an individual in San Francis-
co, California.
OPINION
Petitioner bears the burden of proving that respondent's
determinations are erroneous. Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933). Deductions are strictly a matter of
legislative grace, and petitioner bears the burden of proving
that he is entitled to any deduction claimed. New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
Petitioner attempted to satisfy his burden of proof in this
case principally through his testimony and the Hetz report that
was attached to his 1991 return. We found petitioner's uncor-
roborated testimony at times questionable, general, vague, and
conclusory. Under the circumstances presented here, we are not
required to, and we do not, rely on petitioner's testimony to
sustain his burden of establishing error in respondent's deter-
minations. See Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th
Cir. 1989), affg. T.C. Memo. 1987-295; Geiger v. Commissioner,
440 F.2d 688, 689-690 (9th Cir. 1971), affg. per curiam T.C.
Memo. 1969-159; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
As for the Hetz report, for the reasons discussed below, we place
no weight on that report.
At trial, respondent presented as an expert witness the
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