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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.
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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