Joe Nathan Bryant, Jr. - Page 4

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          claimed by petitioner, there is nothing in this record except               
          petitioner's naked testimony to dispute respondent's                        
          determinations.  Petitioner's testimony, standing alone, is not             
          to be taken as gospel, and it does not carry petitioner's burden            
          of proof.  Halle v. Commissioner, 7 T.C. 245 (1946), affd. 175              
          F.2d 500 (2d Cir. 1949).  Therefore, so far as respondent's                 
          determinations are based upon income and deductions as reported             
          by petitioner, we must sustain respondent.                                  
               There remain, however, several discrepancies between                   
          respondent's determinations herein and the record regarding                 
          petitioner's reported deductions.  Specifically:                            
               1.  For the year 1992, respondent's notice of deficiency               
          purported to disallow $16,449 of business-related deductions                
          under Schedule C, whereas petitioner actually reported $8,011 of            
          such deductions.  Respondent's explanation for this discrepancy             
          is that this was an "error" that respondent had corrected; how or           
          at what time this correction was made we do not know, but it                
          apparently is not in accordance with the income and deductions as           
          reported by petitioner, and we do not see what statutory basis              
          respondent has for making a determination of deficiency based on            
          a "correction".  Sec. 6212.  Likewise for the year 1993,                    
          respondent disallowed $16,439 of petitioner's business expenses             
          under Schedule C, whereas the record herein shows that petitioner           
          actually claimed only $16,119.  We will take the figures as                 

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