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these amounts, or $6,025, was a portion of the $7,025 allowed in
the notice of deficiency. The remaining amount of $1,000 was not
explained in the record.
For convenience, we combine our findings of fact and opinion
on an issue by issue basis. We begin by noting that, as a
general rule, the Commissioner's determinations are presumed
correct, and that the taxpayer bears the burden of proving that
those determinations are erroneous. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are a
matter of legislative grace, and the taxpayer bears the burden of
proving that he or she is entitled to any deduction claimed.
Rule 142(a); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). This includes the burden of substantiation. Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976).
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of the filing
of this petition, petitioner resided in Victorville, California.
Employee Business Expenses
a. Parking Expenses. From January through July 28, 1991,
petitioner was employed by Pacific Bell Yellow Pages (Pacific
Bell) as a telemarketing sales manager of inside sales
representatives. On July 29, 1991, petitioner was promoted by
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