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OPINION
Petitioner bears the burden of showing error in the
determinations in the notice that remain at issue. See Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are strictly a matter of legislative grace, and petitioner bears
the burden of proving that he is entitled to any deductions
claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Petitioner attempted to satisfy his burden of proof through
his own testimony and certain documentary evidence, including the
1995 document, the 1997 document, and certain alleged receipts
for a claimed car rental expense,11 taxi expense, and meal
expenses.12 We found petitioner’s testimony to be questionable
and not credible in certain material respects. We also found the
1995 document,13 the 1997 document, and the alleged car rental
11Petitioner relies on a receipt issued to “Jack Newhart”
for a rental car expense incurred for the period Dec. 23-27,
1995. See supra note 10.
12Petitioner relies on nine claimed meal receipts. Eight of
those nine receipts consist of restaurant chits (chits) that were
removed from certain restaurant bills and that were filled in by
hand. Only four of those eight chits indicate the names of the
restaurants at which petitioner contends he ate meals, the cost
of which he is claiming as rental expense deductions under sec.
212. Two of those four chits also indicate the locations of the
restaurants. Petitioner indicated in his handwriting on each of
the nine claimed meal receipts the individuals who he contends
attended each of the meals in question and the purpose that he
claims for each such meal. Petitioner’s handwriting on two of
the claimed meal receipts indicates that his mother Juanita Demas
attended the meals to which those receipts purportedly refer.
13The 1995 document contains a series of entries claiming
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