- 13 - 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 (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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