Joe Nathan Bryant, Jr. - Page 3

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               1.  Respondent determined that petitioner had received State           
          income tax refunds in the amounts of $424 and $464 in 1992 and              
          1993, which petitioner failed to report.                                    
               2.  Respondent disallowed $16,449 and $16,439, respectively,           
          for the years 1992 and 1993 on account of Schedule C business-              
          related deductions by petitioner.                                           
               3.  With respect to petitioner's itemized deductions under             
          Schedule A on the returns in issue, respondent disallowed $28,985           
          for 1992 and $28,526 for 1993 on account of deductions other than           
          State income taxes paid by petitioner in those years, which                 
          respondent allowed.                                                         
               Where the Commissioner has made a determination of                     
          deficiency in income tax against a taxpayer, such as here,                  
          regarding his income for a given year, the burden of proof on               
          each issue determined by the Commissioner is on the taxpayer.               
          The Commissioner's determination of the deficiencies is                     
          presumably correct.  Rule 142(a); Welch v. Helvering, 290 U.S.              
          111 (1933).                                                                 
               Furthermore, deductions from income are strictly a matter of           
          legislative grace, and the taxpayer bears the burden of proving             
          entitlement to all deductions claimed.  INDOPCO, Inc. v.                    
          Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.               
          Helvering, 292 U.S. 435 (1934).                                             
               So far as respondent's determination of deficiencies is                
          concerned, based upon income and deductions as reported and/or              

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