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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 10,196
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