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telephonic conference with the parties concerning that motion,
the Court allowed the parties a reasonable period of time until
January 26, 1996, within which to finalize and file their opening
briefs. Respondent's opening brief was timely filed. No opening
brief was filed by petitioner. Accordingly, the Court ordered
that (1) respondent's opening brief was to be served on peti-
tioner, (2) respondent was not required to file an answering
brief, and (3) petitioner was not allowed to file either an
opening brief or an answering brief.
Discussion
We note at the outset that petitioner bears the burden of
proving that the determinations in the notice of deficiency are
erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933). We also note that deductions are strictly a matter of
legislative grace, and a taxpayer must meet the specific statu-
tory requirements for any deduction claimed. New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
The scant record in this case consists of petitioner's
testimony. Based on that record, we sustain respondent's income
determinations. We further find on the record before us that
petitioner has failed to show that he is entitled to any deduc-
tions or exemptions in excess of those allowed by respondent3 or
3 Petitioner's general, conclusory, and/or vague testimony
regarding the deductions to which he claims he is entitled for
(continued...)
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