Upon review of the record, we conclude that respondent Tax Appeals Tribunal's determination denying the petition for redetermination of deficiencies or for a refund of personal income taxes imposed for the year 1985 should be upheld. It is well settled that the burden of proof is upon the petitioner to prove an erroneous deficiency assessment by clear and convincing evidence. Here, the Tribunal correctly ruled that petitioner failed to sustain his burden of proving by clear...
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