Maria M. Masloff - Page 5

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            in her basis in certain property that she sold during 1988, and                             
            (3) deductions for 1992 of approximately one-half of certain                                
            mortgage interest in Schedule A and one-half of such interest in                            
            Schedule E.2  The only evidence in the record to support those                              
            contentions is the general, vague, and conclusory testimony of                              
                  Petitioner has the burden of showing (1) error in                                     
            respondent's determinations in the notice and (2) her entitlement                           
            to any new matters that she claimed at trial.  Rule 142(a); Welch                           
            v. Helvering, 290 U.S. 111, 115 (1933).  On the record before us,                           
            we find that petitioner has failed to carry her burden of proof                             
            on those determinations of respondent in the notice that she and                            
            respondent did not resolve in the stipulation and on those                                  
            matters that she raised at trial.                                                           
                  To reflect the foregoing and the agreement of the parties                             
            that is set forth in the stipulation,                                                       

                                                             Decision will be entered                   
                                                       under Rule 155.                                  

            2  Petitioner and respondent agreed in the stipulation that                                 
            petitioner is entitled for 1992 to a Schedule A mortgage interest                           
            deduction in the amount of $13,128.  Although it is not                                     
            altogether clear, it appears that petitioner is now claiming that                           
            she is entitled to deduct about one-half of that interest in                                
            Schedule E.                                                                                 

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