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Respondent also determined in the notice that petitioners
are liable for 1993 for the accuracy-related penalty under
section 6662(a).
OPINION
Petitioners bear the burden of proving that respondent's
determinations in the notice are erroneous. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are
a matter of legislative grace, and the taxpayer has the burden of
showing his or her entitlement to any deduction claimed.
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Petitioner's Automobile Repair Activity
Petitioners' Claimed Schedule C Expenses
Petitioners argue that they are entitled to deduct the
$12,630 net loss that they claimed in their 1993 amended Schedule
C. Respondent counters that petitioners are not entitled to
deduct a net loss with respect to petitioner's automobile repair
activity because, inter alia, petitioner was not engaged in his
automobile repair activity for profit.
Before turning to the arguments of the parties, we shall
address petitioners' contention that respondent has the burden of
proof with respect to petitioner's profit objective under section
183. Although not altogether clear, we construe their argument
to be based on section 183(d). As pertinent here, section 183(d)
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