- 18 - While acknowledging that the burden of proof rests upon the petitioner for this issue, common sense would dictate the consideration of some costs associated with moving the petitioner and his family. Petitioner claims that the Internal Revenue Service had previously agreed "to allocate twenty percent (20%) of this payment toward relocation expenses." Respondent argues that petitioner is required to include in gross income the entire lump-sum payment of $100,000 received from the FBI. Respondent argues that, except for his self-serving testimony: "Petitioner has not offered any evidence to prove he incurred the expenses claimed or that the alleged expenses were deductible." We agree with respondent. There is no basis in the record of this case upon which we can find that some or all of the lump-sum payment should be excluded from petitioner's gross income. According to the record, the FBI intended the payment to award petitioner a share of the seized property, to compensate petitioner for his cooperation, and to defray any relocation expenses he had incurred. The original telex requesting authorization to make the payment states that it "represents a share of the value of United States currency, certificates of deposit, vehicles, residences, farms, and business locations seized as a direct result of the cooperation furnished". RewardsPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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