- 3 - 142(a)(1); Welch v. Helvering, 290 U.S. 111, 115 (1933). Moreover, tax deductions are a matter of legislative grace with a taxpayer bearing the burden of proving entitlement to the deductions claimed. Rule 142(a)(1); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). In 1982, petitioner leased a parcel of land on which he and his family ran a small produce stand out of a moveable type structure. Petitioner contends that, despite his lease, a “group of lawyers” wanted to build a motel on the land. Petitioner claims that when he refused to move, “they took a truck in and took everything that I had”. As a result, petitioner’s produce stand was forced to shut down, and petitioner allegedly sustained a business loss of $10,000. On his 1982 return, petitioner claimed a business loss of $10,000 for his produce stand. Petitioner’s testimony suggests that he expected the Internal Revenue Service (IRS) to reimburse him, in actual dollars, for the business loss claimed on the return. When petitioner did not receive any form of response from the IRS, he continued to claim a business loss of $10,000 on each and every return that he filed with the IRS after 1982 because he wanted “a sense of fairness from the IRS.” 2(...continued) because petitioner has not produced any evidence that establishes the preconditions for its application.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007