Carlton H. Perry - Page 6

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          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 through his own testimony and certain documentary evidence.            
          We found petitioner's testimony at times questionable, general,             
          vague, conclusory, and evasive.  Under the circumstances present-           
          ed here, we are not required to, and we do not, rely on petition-           
          er's testimony to sustain his burden of establishing error in               
          respondent's determinations.  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 documentary evidence on which petitioner             
          relies, for the reasons discussed below, we find that those                 
          documents do not support petitioner's contentions and/or are                
          unreliable.                                                                 
          Motor Home Expenses                                                         
               Section 162(a) generally allows a deduction for ordinary and           
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.3  To be entitled to a deduction            


          3  Sec. 212 allows a deduction for all ordinary and necessary               
          expenses paid or incurred during the taxable year for the produc-           
          tion or collection of income or for the management, conservation,           
          or maintenance of property held for the production of income.               
          Petitioner has not expressly argued that he is entitled to a                
                                                             (continued...)           




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