John K. Jorman, Jr. and Audrey Jorman - Page 6

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          maintained a separate bank account for the real estate activity;            
          however, most of the checks entered into evidence that were drawn           
          on the account were made payable to "cash".  Petitioner described           
          the nature of his real estate activity for years prior to 1991              
          but provided no information concerning what he was doing in 1991.           
               Respondent disallowed the entire moving expense deduction              
          based upon lack of substantiation.  Respondent disallowed all of            
          the deductions claimed on the Schedule C upon the ground that               
          petitioner's real estate activity did not constitute a trade or             
          business within the meaning of section 162(a).  Petitioners claim           
          that they have satisfied all of the provisions of section 217,              
          and with the exception of certain PSI records, rely exclusively             
          on petitioner's testimony to support the amount of the deduction            
          claimed.  Petitioner also claims that he was engaged in some real           
          estate business during 1991 and relies primarily upon his history           
          of such activity in the years 1985 through 1988.                            
               Respondent's determinations, having been made in a notice of           
          deficiency, are presumed correct, and petitioners bear the burden           
          of proving such determinations to be erroneous.  Rule 142(a);               
          Welch v. Helvering, 290 U.S. 111, 115 (1933).  Furthermore,                 
          deductions are a matter of legislative grace, and the taxpayer              
          bears the burden of proving that he is entitled to any deduction            
          claimed.  Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.              
          79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,             

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