- 5 -
years in issue, petitioners listed the "taxable amount" of such
items as $18,039, $21,923, and $23,169, respectively. In
computing the amounts reported on line 17b, petitioners reduced
the amounts shown on line 17a for each year by $10,998, $10,242,
and $10,672, respectively. The amounts of the reductions relate
entirely to the CSRS annuity distributions.
In the notice of deficiency respondent determined that
petitioners were not entitled to the reductions claimed, and, in
addition to other adjustments not in dispute, increased
petitioners' income for each year in issue by the amount of the
reduction claimed by petitioners in connection with petitioner's
CSRS annuity distributions.6
Respondent's determinations, having been made in a notice of
deficiency, are presumptively correct, and petitioners bear the
burden of proving that such determinations are erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Although we are unable completely to follow petitioners'
arguments, it appears that they take the position that the
reductions, or exclusions, were proper for two reasons. First,
they claim that the reductions reflect amounts that they repaid
to OPM during the relevant year. As best as we can tell from the
record, petitioners allege that petitioner repaid or contributed
6In the notice of deficiency, respondent erroneously
overstated the amount of the 1991 adjustment on this item. The
parties stipulated that the proper amount of the adjustment
should have been $10,672.
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