Albert C. Johnson - Page 11

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          gross receipts for purported cash amounts petitioner received from          
          others on behalf of Mr. Stennett and the Vanderhaydens.                     
               To summarize, because petitioner failed to keep adequate books         
          and records and did not file Federal income tax returns for the             
          years in issue, we conclude that respondent properly reconstructed          
          petitioner's income for the years in issue with one exception               
          relating to tax year 1990.  That exception relates to $9,500 which          
          petitioner claims, and we accept as true, belonged to his father,           
          and resulted from the sale of a bull purchased and resold by                
          petitioner's father. Thus, petitioner's gross receipts as                   
          determined by respondent for 1990 should be reduced by $9,500.              
          Issue 2.  Expenses                                                          
               We next address whether petitioner is entitled to deductions           
          for expenses in excess of those agreed upon through an analysis of          
          petitioner's checks.  Specifically, petitioner claims entitlement           
          to deductions for (a) cash expenditures for cattle feed, (b) a              
          portion of the expenses for a trip to Belgium in 1990, and (c)              
          depreciation for a barn.                                                    
               As often stated, deductions are a matter of legislative grace.         
          New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).                
          Taxpayers bear the burden of establishing that they are entitled to         
          the claimed deductions.  Rule 142(a); Welch v. Helvering, 290 U.S.          
          111, 114 (1933).  This includes the burden of substantiating the            

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