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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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