- 5 - respect to any deductions that petitioner is claiming for each of the years at issue, deductions are strictly a matter of legisla- tive grace, and petitioner bears the burden of proving that he is entitled to any deductions claimed. INDOPCO, Inc. v. Commis- sioner, 503 U.S. 79, 84 (1992). In support of his position that he is entitled to deduct for each of the years at issue claimed Schedule C expenses in excess of the amount conceded by respondent, petitioner relies on his testimony. We found petitioner’s testimony to be general, conclusory, vague, self-serving, and uncorroborated in material respects. We shall not rely on petitioner’s testimony to support his position with respect to the claimed deductions at issue. On the record before us, we find that petitioner has failed to carry his burden of showing that he is entitled to deduct for each of the years at issue claimed Schedule C expenses in excess of the amount conceded by respondent. We now turn to the determination in the notice that peti- tioner is liable for each of the years at issue for the accuracy- related penalty under section 6662(a). According to respondent, petitioner is liable for that penalty because of negligence or disregard of rules or regulations under section 6662(b)(1). On the record before us, we find that respondent has carried respon- dent’s burden of production under section 7491(c) with respect to the accuracy-related penalty under section 6662(a) for each ofPage: Previous 1 2 3 4 5 6 Next
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