- 5 - Respondent issued petitioners a notice of deficiency for their 1994 tax year. In the notice of deficiency, respondent disallowed petitioners' claimed partnership loss carryover and their charitable contribution deduction. Respondent adjusted petitioners' claimed medical expense deduction and earned income credit due to the increases in petitioners' adjusted gross income. Respondent determined that petitioners were liable for the self-employment tax and for the accuracy-related penalty. Respondent also determined that petitioners were entitled to a self-employment tax credit. While no deficiency was determined for 1993, the statement of adjustments attached to the notice of deficiency included adjustments to petitioners' 1993 Federal income tax return. The adjustments for 1993 consisted of the disallowance of petitioners' claimed partnership loss carryover from 1992, charitable contribution deduction, and medical expense deduction. Respondent also made an adjustment to petitioners' claimed earned income credit for 1993 as a result of the adjustment to petitioners' adjusted gross income. Discussion We begin by noting that the Commissioner's determinations are presumed correct. See Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions are a matter of legislative grace, and the taxpayers bear the burden of proving that they arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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