-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.
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