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B. Social Security Payments
Respondent determined that petitioner received Social
Security payments totaling $14,538 in 2000. Petitioner contends
that he received only $13,876. Petitioner bears the burden of
proving that respondent’s determination is incorrect. See Rule
142(a).
Respondent’s determination was based on a third-party payor
statement from the Social Security Administration indicating that
petitioner received payments totaling $14,538 in 2000.
Petitioner testified that his Social Security benefits increased
after the first quarter of 2000. He claims that the $14,538 was
arrived at by multiplying the increased monthly benefit by 12,
which did not take into account the lower monthly benefit
received in the first 3 months of the year. Petitioner did not
provide any bank statements, Social Security statements, or other
documentation to support his argument. Accordingly, we find that
petitioner has not met his burden of proving respondent’s
determination is incorrect. We hold that petitioner received
Social Security payments totaling $14,538 in 2000.
C. Certain Deductions Claimed by Petitioner
Next, we must consider whether petitioner is entitled to
certain deductions. Deductions are a matter of legislative
grace, and the taxpayer bears the burden of proving he is
entitled to the deductions. INDOPCO, Inc. v. Commissioner, 503
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