- 9 - $371,600. Interest was provided for at 10 percent. Additionally, petitioner agreed to make principal only payments of $5,000 to Mark Tietig each month beginning November 1, 1992. There was a dispute between Mark Tietig and a law firm over fees incurred in petitioner’s bankruptcy case.12 The settlement agreement provided that if it was determined that Mark Tietig owed any additional attorney’s fees, then petitioner would pay them to Mark Tietig, and this amount would be added to the amount petitioner owed Mark Tietig under the original 1983 promissory note and agreement and secured by the same collateral. B. Discussion Deductions are a matter of legislative grace, and the burden of showing the right to deductions is on the taxpayer. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Petitioner argues that he is entitled to a $32,241 deduction in 1993 for payments that he allegedly made to his son Mark Tietig. The deduction was not claimed on petitioner’s Federal income tax return for that year or disallowed by respondent in his notice of deficiency; rather, the issue was raised for the first time by petitioner in his petition to the Tax Court. Petitioner did not explain in his petition or on brief how he arrived at $32,241 as a deduction or why it is deductible. 12Petitioner filed for bankruptcy on Sept. 22, 1988.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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