The following excerpt is from Geiger v. CIR, 440 F.2d 688 (9th Cir. 1971):
The Commissioner's determination was presumptively correct. Herbert v. C.I.R., 377 F.2d 65 (9th Cir. 1967). The burden rested upon the taxpayer to prove that she was entitled to business expense deductions in excess of those allowed by the Commissioner and that moneys she had received but had not reported were not taxable as income.
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