15
for 1991 and 1992 by mid-April 1997, but he did not do so.
Materials not provided in compliance with our pretrial orders may
be excluded from evidence. Moretti v. Commissioner, 77 F.3d 637,
644 (2d Cir. 1996); Kodak v. Commissioner, T.C. Memo. 1991-485,
affd. without published opinion 14 F.3d 47 (3d Cir. 1993). For
that reason we sustained respondent's objection.
C. Whether Petitioner Is Entitled to More Deductions Than
Allowed by Respondent for 1991 and 1992
Respondent's determinations in the notices of deficiency are
presumed to be correct, and petitioner bears the burden of
proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933); Rockwell v. Commissioner, 512 F.2d 882, 885 (9th
Cir. 1975), affg. T.C. Memo. 1972-133. Deductions are a matter
of legislative grace; petitioner must prove that he is entitled
to any deductions claimed. INDOPCO, Inc. v. Commissioner, 503
U.S. 79, 84 (1992).
Petitioner deducted more Schedules C and E business expenses
than respondent allowed for 1991 and 1992. Respondent disallowed
some of these deductions because petitioner did not substantiate
them or show that he had a business purpose for the expenses.
A taxpayer may deduct ordinary and necessary expenses paid
or incurred during the taxable year in carrying on a trade or
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