Astrida Terauds - Page 8

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          was no taxable event as to such stock.  Another contention by               
          petitioner is that, of the amounts listed above, two of the stock           
          sales listed, Harris Trust Co. in the amounts of $10,710 and                
          $14,917, were incorrect and should have been, respectively,                 
          $4,310 and $5,967.  Petitioner presented to the Court a Form 1099           
          from the Harris Trust Co. of New York that reflected a cash                 
          payment to petitioner of $5,967.50 during 1986; however,                    
          petitioner failed to prove that this Form 1099 related to any of            
          the Harris Trust Co. transactions listed above.  The Form 1099              
          for $5,967.50 presented by petitioner did not indicate that it              
          was a corrected or amended Form 1099.  Petitioner's position is             
          not only vague but contradictory because, in support of her first           
          argument, she acknowledged that the transactions at issue                   
          involving stock totaled $82,529 during 1986.  To argue that two             
          of the amounts making up the $82,529 are incorrect is simply                
          contradictory to her acknowledgment that her stock transactions             
          that year amounted to $82,529.  On this record, petitioner has              
          not satisfied her burden of proving that respondent's                       
          determination of her long-term capital gains for 1986 is                    
          incorrect.  Respondent, therefore, is sustained on this issue.              
          3.  Claimed Deduction for Expenses Relating to Rental Property              
               The third issue is whether petitioner is entitled to a                 
          deduction for expenses incurred in connection with rental                   
          property during 1986 that was not allowed by respondent.  In the            

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