- 6 - burden of proving that the amounts at issue were properly designated as a rental allowance by official church action before payment. See Rule 142(a). The record is devoid of any such evidence.2 To the extent it addresses this issue, Mrs. Logie's testimony suggests that the characterization of part of petitioners' income as parsonage allowances was an afterthought.3 Accordingly, we sustain respondent's determinations with respect to the amounts claimed as parsonage allowances. See Boyer v. Commissioner, 69 T.C. 521, 533 (1977); Eden v. Commissioner, 41 T.C. 605, 607 (1964). Schedule C Deductions Respondent disallowed a duplicative $1,400 deduction for supplies expenses and disallowed $1,102 of claimed telephone expenses as being personal in nature. The Commissioner's determinations are presumed correct, and the taxpayer bears the burden of proving that those determinations are erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Although petitioners' brief alludes in its statement of facts to respondent's disallowance of these claimed Schedule C expenses, 2 Petitioners' W-2 forms do not constitute substantiation in this regard because, among other reasons, they were issued after the payments were made. 3 Mrs. Logie testified that she had "been researching the Internal Revenue Code and * * * read about the housing allowance" and felt it "would be unjust and unfair not to include that as part of" their joint Federal income tax return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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