- 7 - Respondent's determinations in the statutory notice of deficiency are presumed to be correct, and petitioners bear the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are strictly a matter of legislative grace, and petitioners bear the burden of proving their entitlement to any deductions claimed. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). The first issue for decision is whether petitioners are entitled to charitable contribution deductions for 1991 and 1992 in excess of the amounts allowed by respondent. Petitioners claimed charitable contribution deductions in the amounts of $11,101 and $12,000 on their 1991 and 1992 returns, respectively. In the statutory notice of deficiency, respondent disallowed $9,139 and $9,888 of these claimed amounts, respectively. Petitioners argue on brief that they are entitled to deductions for the following charitable contributions that have not been allowed by respondent: 1991 1992 Penrith Church (Cash) $3,000 $3,000 Penrith Church (Goods) 2,998 4,004 Senior Women's Ministries 808 792 Vietnam Veterans of America 2,270 2,400 Total 9,076 10,196Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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