- 6 -
terminated upon Maria's death. The payments do not therefore
satisfy the requirement of section 71(b)(1)(D). Respondent's
determination as to this issue is therefore sustained.
Petitioner offered no evidence that he made the $190 payment
which he claimed as a deduction, and, as stated previously, no
legal argument of any type was made on brief. Petitioner bears
the burden of proof. Rule 142(a). Respondent's determination
must be sustained as petitioner has failed to satisfy his burden
of proof on this issue.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011