Charles Michael Snyder - Page 8

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          assessed the tax shown on petitioner’s returns, and petitioner              
          bears the burden of proving his returns are inaccurate.                     
               Petitioner’s second argument is that his tax returns do not            
          reflect losses incurred in connection with his oil and gas                  
          interests.  Petitioner concedes that he does not have records to            
          support the claimed losses.  Petitioner asserts that the parties            
          involved in the litigation of his oil and gas interests have                
          refused to provide him with any information, thereby making it              
          impossible for him to provide substantiation.  For reasons that             
          are not clear, however, petitioner insists that respondent has or           
          should have such information in respondent’s administrative file.           
          Petitioner therefore believes that respondent has evidence of the           
          losses and should reduce petitioner’s outstanding tax liabilities           
               Deductions are a matter of legislative grace, and a taxpayer           
          generally bears the burden of proving that he is entitled to the            
          deductions claimed.  See Rule 142(a); INDOPCO, Inc. v.                      
          Commissioner, 503 U.S. 79 (1992).  A taxpayer bears the burden of           
          proving a deductible loss, as well as the extent and amount of              
          the loss.  Citron v. Commissioner, 97 T.C. 200, 207 (1991).                 
               In this case, petitioner has not produced any credible                 
          evidence that he sustained a deductible loss in connection with             
          his oil and gas interests.  Petitioner believes that respondent             
          has relevant information that petitioner has been unable to                 

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