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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.
Discussion
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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