Debra D. McNair - Page 8

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          Petitioner admitted that her 2000 return contained many errors,             
          and with the assistance of her authorized representative, Clark,            
          petitioner prepared a draft amended 2000 return to facilitate               
          settlement.  In the unfiled draft amended 2000 Schedule C,                  
          petitioner claimed $1,929 for transportation expenses (mileage              
          from first job to second job), $500 in tax preparation costs,               
          $215 for office expenses, $333 for supplies, and $356 for a                 
          cellular telephone.  By notice of deficiency, respondent                    
          disallowed all but $90 of petitioner’s Schedule C deductions.               
          Respondent’s determination of the business deductions allowed to            
          petitioner for 2000 was equal to 10 percent of the gross receipts           
          reported on petitioner’s 2000 Schedule C.  At trial petitioner              
          admitted that she had no substantiation of her business expenses            
          for 2000, except for a bill from her tax return preparer for                
          $408.  She conceded all deductions for business expenses in                 
          excess of those allowed in respondent’s notice of deficiency,               
          except for claims for deductions for business transportation                
          expenses and for the tax return preparation bill.                           
               In general, the Commissioner’s determinations are presumed             
          correct, and the taxpayer bears the burden of proving that those            
          determinations are erroneous.  Rule 142(a).  Section 7491(a) does           
          not apply in this case to shift the burden of proof to                      
          respondent.  Petitioner has neither alleged that section 7491(a)            

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