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Petitioners reported income and adjustments to income on
their 1992 return as follows:
Item of Income Amount
Wages $58,796
Interest 630
Dividend 591
Capital gain 36
Other income 1,033
Total income 61,086
Adjustment to Income
IRA deduction $2,000
IRA deduction 2,000 4,000
Adjusted gross income 57,086
In the notice of deficiency, respondent determined that
petitioners were not entitled to the claimed IRA deductions.
Respondent determined that each petitioner was an active
participant in a pension plan qualified under section 401(a)
during 1992. It is well settled that deductions are a matter of
legislative grace, and petitioners bear the burden of proving
entitlement to any claimed deductions. INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); Nelson v. Commissioner, 30
T.C. 1151, 1154 (1958). Moreover, respondent's determinations
are presumed correct, and it is petitioners' burden to establish
error. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933).
Petitioners do not appear to dispute that their respective
employers maintained pension plans qualified under section
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