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Petitioner contends that he has no deficiencies in income
tax because he deposited more funds with respondent than the
amount of taxes respondent contends he owes for the years in
issue. We disagree. First, petitioner has not shown that he
deposited funds with respondent. Second, the term “deficiency”
is generally defined by statute as the difference between the
total amount of tax that the Commissioner determines should have
been reported on the return and the amount that the taxpayer
reported on the return. Sec. 6211(a). The amount of a
deficiency is not reduced by amounts of tax deposited by or
withheld from the taxpayer.
Petitioner testified that the payments he received from the
Federal Government were nontaxable disability payments. His
testimony was uncorroborated. We are not convinced that
petitioner was paid on account of disability in any of the years
in issue.
2. Whether Petitioner Had $1,092 in Income From Lottery
Winnings in 1993
Petitioner contends that he is not taxable on the $1,092
that he won in the lottery in 1993 because he and another
individual shared the winnings. Petitioner’s claim is
unconvincing because he did not identify the other alleged
lottery winner or otherwise corroborate his claim.
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