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Respondent determined that petitioner had failed to file
timely returns for the years in issue, that petitioner had income
based on reports by payers, and that petitioner was entitled to
the standard deduction for each year.
OPINION
Petitioner bears the burden of proving that respondent's
determinations are erroneous. See Rule 142(a). With the
exception noted below, however, she has failed to present
evidence from which we can conclude that she is entitled to
exclude any income or deduct any expenses beyond the amounts
previously conceded by respondent. Her testimony was vague and
inconclusive. Notwithstanding the Court's specific suggestion
that the parties stipulate to additional documents after trial,
the only additional information submitted by petitioner led to
respondent's conceding that petitioner contributed $1,300 to the
Combined Federal Campaign in 1994.
Petitioner essentially asks us to accept the amounts claimed
on her returns in the categories of those items remaining in
dispute. Those returns, however, are not proof of the amounts
reported on the returns. Moreover, the stipulation specifically
contradicts the correctness of some of the items claimed by
petitioner. She acknowledges:
Wherein the petitioner provided respondent proof of
itemized deductions contained in the stipulation of
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