Eileen A. Akers - Page 5




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               Petitioner reported wage income in each of the years in                
          question from the Norwich public schools in Norwich, Connecticut.           
          She also reported dividend and interest income.                             
               Petitioner timely filed a petition in this Court.  A                   
          stipulation of facts with accompanying exhibits was received at             
          trial, as well as the testimony of petitioner’s husband.                    
          Petitioner attempted to introduce additional exhibits with her              
          posttrial brief, but the record having been closed, these                   
          documents were not admitted into evidence.                                  
                                     Discussion                                       
               Respondent’s determination is presumed correct.  Rule                  
          142(a).  Deductions are a matter of legislative grace, and a                
          taxpayer bears the burden of proving entitlement to any deduction           
          claimed.  New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440              
          (1934); Hradesky v. Commissioner, 65 T.C. 87, 89 (1975), affd.              
          per curiam 540 F.2d 821 (5th Cir. 1976).  Failing to introduce              
          credible evidence to shift the burden of proof under section                
          7491(a), petitioner bears the burden of proving respondent’s                
          determination is incorrect.                                                 
               Petitioner raises several arguments concerning the                     
          procedural history of this case prior to the issuance of the                
          notice of deficiency.  These arguments do not relate to the                 










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