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The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden of proof is on
the taxpayer to prove that the determinations are in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Section 61 provides that gross income means all income from
whatever source derived, including wage and salary income. Sec.
1.61-1, Income Tax Regs. Accordingly, the wages received by
petitioner during 1981 totaling $12,031.22 constitute taxable
income. Respondent is sustained on this issue.
At trial, petitioner claimed that she is entitled to
deductions for medical expenses and employee business expenses
for travel incurred by her during 1981. The medical expenses
incurred by petitioner relate to two car accidents, in February
and October 1981, and a 30-day substance abuse program. With
respect to the car accidents, petitioner claims that emergency
room costs of approximately $600 and chiropractic treatments of
approximately $350 were not covered by insurance. With respect
to the substance abuse program attended by petitioner in June
1981, petitioner claims that her medical insurance did not cover
$1,960 of the $9,780 cost of the program. Other than one
chiropractic statement indicating charges of $94 on December 21,
1981, petitioner did not present any documentary evidence to
substantiate the claimed expenses.
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