- 6 - 34(b)(5), provide no statements of the facts upon which they base assignments of error. At trial, petitioners raised frivolous arguments characteristic of tax protesters.4 They argued that their wages should not be taxable because they have so little left after they pay their expenses (other than their taxes, apparently). Petitioners’ arguments merit no further discussion. See Heisey v. Commissioner, T.C. Memo. 2002-41, affd. 59 Fed. Appx. 233 (9th Cir. 2003). We sustain respondent’s determinations in the notices of deficiency as to the amounts of petitioners’ unreported taxable incomes for the years at issue. B. Deductions In their petitions and at trial, petitioners alleged vaguely and without reference to supporting facts that they are entitled to various deductions. Deductions are a matter of legislative grace; petitioners bear the burden of proving entitlement to them. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Respondent has stipulated that in 2003 Mr. Jackson paid $11,413 of mortgage interest and Ms. Jackson paid $6,137 of mortgage 4 For instance, Mr. Jackson contended that he was entitled to “full and complete relief from this proceeding” because of “invalid OMB number on the 1040 form”. Petitioners did not raise this argument in their petitions. In any event, the argument is without merit. See, e.g., United States v. Dawes, 951 F.2d 1189, 1191 (10th Cir. 1991); United States v. Hicks, 947 F.2d 1356, 1359 (9th Cir. 1991); Wheeler v. Commissioner, 127 T.C. 200, 208 n.12 (2006). In addition, at trial Mr. Jackson sought to rely upon a letter which he had previously sent to the Court, demanding that the Court “Verify authenticity of your authority”.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007