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from an attorney named Bill Shernoff, and it was petitioner and
Mr. Ludlow’s decision to deposit it in her Merrill Lynch account
instead of the general operating account.
Petitioner could not remember anything regarding the nature
of the $3,750 and $5,000 September 17, 1990, deposits or the $825
December 6, 1990, deposit. Respondent has proven a likely source
of these deposits, and petitioner has not established the
nontaxable nature of these deposits; accordingly, they are
included as gross income. Commissioner v. Glenshaw Glass Co.,
supra at 431; Davis v. United States, supra at 334-335; Manzoli
v. Commissioner, supra.
B. Schedule C Deductions
Deductions are a matter of legislative grace; petitioner has
the burden of showing that she is entitled to any deduction
claimed. Rule 142(a); New Colonial Ice Co. v. Helvering, 292
U.S. 435, 440 (1934). Taxpayers are required to maintain books
and records sufficient to establish the amount of their income
and deductions. Sec. 6001; DiLeo v. Commissioner, supra at 867.
Respondent disallowed Schedule C expenses petitioner claimed
relating to the law firm. Petitioner relies on her own testimony
to substantiate these deductions. The Court is not required to
accept petitioner’s unsubstantiated testimony. See Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.
593 (1964). We found petitioner’s testimony to be general,
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