- 10 - OPINION 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 filePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011