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Petitioner invites the Court implicitly to wade through the
numerous checks in the record, calculator in hand, to come up
with the purported amounts of alleged business expenses. We
decline this invitation. See Stringer v. Commissioner, 84 T.C.
693 (1985), affd. without published opinion 789 F.2d 917 (4th
Cir. 1986)(wherein the Court refused to sift through a voluminous
and unintelligible record without the aid of a brief).
Deductions are a matter of legislative grace, and taxpayers bear
the burden of proving they are entitled to claimed deductions.
See Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1934);
6(...continued)
18. The corporations paid the legal fees of attorneys
who represented some of the test-case petitioners in
Dixon v. Commissioner.
* * * * * * *
20. The corporations paid rent on office space during
the years in question.
21. The corporations paid for telephone service during
the years in question.
* * * * * * *
29. In determining the income derived or to be derived
by the corporations, the Commissioner did not take into
account any deductions that the corporations would have
had for ordinary business expenses.
30. The Commissioner was required to take into account
those business deductions which the Commissioner had
evidence of when determining the alleged deficiency of
Kersting.
Petitioner's Post-Trial Brief, pp.4-5 (citations omitted)
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