What is the burden of proving a deficiency determination made by the Commissioner?

The Commissioner's deficiency determinations are presumed correct, and the petitioner bears the burden of proving them incorrect in a proceeding in tax court. Hokanson v. Commissioner, 730 F.2d 1245, 1249 (9th Cir.1984). The petitioner is required to give clear and concise assignments of each error allegedly committed by the Commissioner in its determination of deficiency, and clear and concise statements of the facts which support the assignments of error. 26 U.S.C. 7453 Tax Ct.R. 34(b)(4), (5).