- 4 - 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 asPage: Previous 1 2 3 4 5 6 Next
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