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an investigation of his return preparer, Space Coast. Petitioner
also complains that the IRS failed to respond to his inquiries.
The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden of proof is on
the taxpayer to show that the determinations are incorrect. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are a matter of legislative grace, and petitioner bears the
burden of proving entitlement to any claimed deductions. New
Colonial Ice Co. v. Helvering, 292 U.S. 435 (1934).
Section 162(a) permits a deduction for "ordinary and
necessary" expenses incurred while carrying on a trade or
business. Since petitioner is an employee, any deductions to
which he might be entitled would be included as employee expense
deductions on Schedule A. Primuth v. Commissioner, 54 T.C. 374,
377 (1970).
Petitioner has failed in his burden of proof. Petitioner
did not present any documents or testimony in this case upon
which we can make a finding that there was a business purpose to
the claimed employee expenses. In fact, petitioner testified
that some of the expenses related to visiting family members.
Thus, there is no question but that some of the claimed expenses
are personal in nature and nondeductible. Sec. 262.
With respect to petitioner's complaints that he was unfairly
selected for examination, we note that the Commissioner, in an
attempt to ascertain the correctness of a taxpayer's return, may
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