- 5 - 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 thePage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007