-14- such cases we are cautioned to bear heavily against the taxpayer "whose inexactitude is of his own making." Id. at 544. Accordingly, based solely on testimony at trial, we find that petitioner paid expenses connected with his artist activity equal to the income reported therefrom for each of the 1988-91 taxable years. Such expenses are deductible pursuant to section 183(b). Additions to Tax Finally, respondent made further determinations of additions to tax under section 6651(a) for 1988 thorough 1990, section 6653(a)(1) for 1988, and section 6654 for 1989 and 1990, and an accuracy-related penalty under section 6662(a) for 1991. As to these matters, the burden of proof is upon petitioner. Rule 142(a); Welch v. Helvering, supra at 115. Petitioner presented nothing on these subjects at trial and, accordingly, we sustain respondent. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011