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under section 7491(a). With respect to any deductions that
petitioner is claiming for each of the years at issue, deductions
are strictly a matter of legislative grace, and petitioner bears
the burden of proving that he is entitled to any deductions
claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
In support of his position that he is entitled (1) for the
taxable year 2000 to Schedule A deductions in excess of those
allowed by respondent, (2) for the taxable years 1999 and 2000 to
Schedule C deductions claimed in his 1999 return and his 2000
return, respectively, and (3) for the taxable year 1999 or the
taxable 2000 to a claimed rental loss deduction,3 petitioner
relies on his testimony and certain exhibits. We found peti-
tioner’s testimony to be general, conclusory, vague, and uncor-
roborated in material respects. We shall not rely on peti-
tioner’s testimony to support his position with respect to the
claimed deductions at issue. The exhibits on which petitioner
relies to support his position with respect to those claimed
deductions consist of copies of (1) a letter from the Minnesota
Department of Revenue to petitioner with respect to his 1996
Minnesota income tax return, (2) a letter to petitioner from the
3The $200,000 rental loss deduction to which petitioner
contends he is entitled for the taxable year 1999 or the taxable
year 2000 relates to the same claimed loss as petitioner’s
claimed $200,000 Schedule A loss and petitioner’s claimed
$200,000 Schedule C loss. Petitioner testified that since the
1980s he has been claiming the same $200,000 deduction in his tax
returns.
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