Thomas C. Pride, Sr. - Page 4

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          determined that petitioner received unreported interest income of           
          $13.                                                                        
               A taxpayer generally must keep records sufficient to                   
          establish the amounts of the items reported on his Federal income           
          tax return.  Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.             
          In the event that a taxpayer establishes that a deductible                  
          expense has been paid but is unable to substantiate the precise             
          amount, we generally may estimate the amount of the deductible              
          expense bearing heavily against the taxpayer whose inexactitude             
          in substantiating the amount of the expense is of his own making.           
          Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).  We             
          cannot estimate a deductible expense, however, unless the                   
          taxpayer presents evidence sufficient to provide some basis upon            
          which an estimate may be made.  Vanicek v. Commissioner, 85 T.C.            
          731, 743 (1985).1                                                           
               The first deduction in dispute is the deduction for mortgage           
          interest.  Mortgage interest generally is deductible under                  
          section 163(a), subject to the requirements of section 163(h).              
          Petitioner argues that the $1,023 disallowed by respondent                  
          represents interest he paid on a second mortgage.  Petitioner,              
          however, was unable to provide any substantiation for this second           


          1Where petitioner has failed to provide the required                        
          substantiation, as discussed in detail below, the burden of proof           
          does not shift to respondent pursuant to sec. 7491(a) and instead           
          remains on petitioner.  Sec. 7491(a)(2)(A); Rule 142(a).                    




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