Henry F. K. Kersting - Page 15




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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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