Regina B. Jackson - Page 4

                                        - 4 -                                         

               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.                                       
               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                    

Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011