Michael W. Allen - Page 9

          exemption applies.  See Hoptowit v. Commissioner, supra at 145-             
          148; Jourdain v. Commissioner, supra.  Moreover, petitioner has             
          introduced no evidence to prove this adjustment was appropriate.            
          Accordingly, we sustain respondent’s disallowance of this                   
          IV. Additional Deductions                                                   
               Petitioner claims on brief, despite not having any documents           
          to substantiate his expenses, that he is entitled to certain                
          deductions beyond those he originally reported on his returns for           
          the years at issue.  For example, petitioner claims he lives in             
          an empowerment zone and/or an enterprise community and is                   
          therefore entitled to additional or increased deductions, such as           
          increased depreciation deductions.  Petitioner also claims that             
          he is entitled to deduct certain expenses, such as depreciation,            
          insurance, mileage on his car, house expenses, office expenses,             
          and miscellaneous expenses for items such as clothing and                   
          cleaning, and personal deductions.  We are thus asked to decide             
          whether petitioner is entitled to deductions in excess of those             
          reported on his returns.                                                    
               We begin with two fundamental principles of tax litigation.            
          First, as a general rule, the Commissioner’s determinations are             
          presumed correct, and the taxpayer bears the burden of proving              
          that these determinations are erroneous.7  Rule 142(a); see                 

               7This principle is not affected by sec. 7491(a), because, as           
          described previously, petitioner failed to substantiate claimed             
          expenses and failed to maintain required records.  See sec.                 
          7491(a)(2)(A) and (B).  Accordingly, the burden of proof remains            

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