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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.
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