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Discussion
Petitioners bear the burden of proving that the determina-
tions in the notice are erroneous. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Except for the general,
vague, and conclusory testimony of petitioner Meredith White,
petitioners presented no evidence to support their positions with
respect to the issues that remain in this case.
On the record before us, we find that petitioners have
failed to establish that they are entitled to the depreciation
deductions claimed in Schedules C of their returns for the years
at issue.3 We further find on that record that petitioners have
failed to establish that they are entitled to deduct $3,074 and
$2,918 for 1994 and 1995, respectively, which they expended
during those years to purchase and install doors and glass in,
and to undertake additional construction with respect to, the
unfinished portion of the Building.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
3Respondent concedes on brief that respondent erroneously
calculated the depreciation deductions to which petitioners are
entitled for the years at issue. Respondent’s concession shall
be taken into account in the computations under Rule 155.
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Last modified: May 25, 2011