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under section 6651(a)(1), for failure to file timely Federal
income tax returns and for the accuracy-related penalty under
section 6662(a) for negligence or disregard of rules or
regulations for all years at issue. At trial, respondent
conceded that petitioner was entitled to itemized deductions for
charitable contributions of $1,480, $1,252, and $1,127,
respectively, for 1989, 1990, and 1991. Respondent also conceded
petitioner's entitlement to an additional deduction for $4,549
for home mortgage interest and an additional deduction of $3,081
for real estate taxes for 1992.
The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden is on the
taxpayer to prove that the determinations are in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933). A taxpayer is
required to maintain records sufficient to establish the amount
of his or her income and deductions. Sec. 6001.
The first issue is whether petitioner received unreported
interest income of $188 and $170 for 1991 and 1992, respectively.
Based on information reported to respondent by payers, respondent
determined that petitioner received unreported interest income of
$188 from United Postal Savings Association for 1991, and
unreported interest income of $43 from United Postal Savings
Association and $127 from Lafayette Life Insurance Company for
1992. Section 61 provides that gross income includes "all income
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