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of deficiency are presumed to be correct, and petitioner bears
the burden of proving otherwise. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Section 61(a) defines gross income to mean all income from
whatever source derived including, but not limited to,
compensation for services, including fees, commissions, fringe
benefits, and similar items. Sec. 61(a)(1).
Petitioner contends that the amounts he received from
Florida Realty are not includable in his gross income because
such amounts were reimbursements for amounts that he paid to
maintain the Guilford rental property. Alternatively, he argues
that, if such amounts are includable in income, he should be
entitled to business expense deductions for the amounts that he
advanced on behalf of Florida Realty. Petitioner further claims
that he is entitled to business expense deductions for certain
amounts he paid to wind up his law practice, subsequent to his
disbarment.
Petitioner has failed to meet his burden of proof. Rule
142(a). He did not comply with the requirements of the standing
pretrial order. He has not shown good cause for his failure to
exchange his documents with respondent as required by the
pretrial order, and the Court did not receive them in evidence.
His testimony was disjointed, contradictory, and, at times,
incomprehensible.
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