- 15 - 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)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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