John Franklin Foust - Page 10

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               Respondent’s determinations are entitled to a presumption of           
          correctness, and petitioner bears the burden of proof with                  
          respect to all issues in this case.  Rule 142(a).  Petitioner               
          must substantiate the amounts and payments of claimed expenses              
          and demonstrate the validity of his claims of deductions                    
          therefor.  Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975),              
          affd. per curiam 540 F.2d 821 (5th Cir. 1976).                              
               Each of respondent’s determinations arose from one aspect or           
          another of petitioner’s farming operations in prior years.                  
          Because of his failures to maintain and offer in evidence records           
          and receipts or other required documentation, petitioner has not            
          carried his burden of proof and persuasion on any of his                    
          substantive claims.  By reason of his failures to provide any               
          explanation or justification for his errors and omissions in the            
          preparation and filing of his 1989 return, petitioner has not               
          carried his burden on the addition and penalty issues.                      
          Issue 1:  Farm Rents                                                        
               Petitioner contends that Cheyenne owed Mesa $60,000 and                
          Teton $50,000 for rental obligations incurred by Cheyenne and               
          petitioner in years prior to 1989.                                          
               Petitioner did not schedule any such claims against himself            
          in his bankruptcy proceeding, and the bankruptcy petitions he               
          filed on behalf of Cheyenne were dismissed for failure to file              

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