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deductions beyond those conceded by respondent. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
Although the Court ordered posttrial briefs, neither party
complied with Rule 151(e)(3). Respondent’s brief purported to
request findings of fact, but many of the proposed findings
recited testimony and described exhibits; some merely
incorporated paragraphs from the stipulation, such as “Attached
as Exhibit 25-J are petitioner’s responses to respondent’s
Interrogatories. (Stip. para. 1)”. Petitioner’s answering brief
did not address the proposed findings of fact or the evidence.
Neither brief served the purpose of assisting the Court in
dealing with vague testimony and numerous documents. See
Stringer v. Commissioner, 84 T.C. 693, 705 (1985), affd. without
published opinion 789 F.2d 917 (4th Cir. 1986). The arguments
made by petitioner, to the extent that they are intelligible, are
refuted by well-established law. The burden of proof does not
affect the outcome of this case, because the evidence of the
inherently personal nature of the deductions claimed by
petitioner outweighs the implausible testimonial assertions by
him and his witnesses.
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