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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". Rewards
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