Feliciano and Debora Ribera - Page 6

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          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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