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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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