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Petitioner bears the burden of proving that respondent erred in
her determination. Rule 142(a). Petitioner has failed to prove
that the amounts received from Flair were not income.
Consequently, we sustain respondent's determination on this
issue.
B. NOL Issue
Petitioner argues that she is entitled to an NOL carryover
deduction generated by losses in Country Club. Petitioner wants
the Court to allow her deductions for Country Club's losses but
not to take into account the section 1231 gain or income from
discharge of indebtedness shown on Country Club's 1989 tax
return, which exceeded the losses. Deductions are a matter of
legislative grace; petitioner has the burden of showing that she
is entitled to any deduction claimed. New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934). Petitioner offers her 1989
tax return as proof that she is entitled to a NOL deduction. A
tax return is merely a statement of a taxpayer's position and is
not evidence of the correctness of the figures and information
contained therein. Wilkinson v. Commissioner, 71 T.C. 633, 639
(1979). Petitioner has not proved either the fact or the amount
of any net operating loss for 1990 or 1991 in excess of the
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