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HEH returns (prepared, signed, and filed by Sparkman less than 3
weeks before trial) and attachments thereto, and Sparkman’s
returns for the years at issue. We need not accept these figures,
and we decline to do so. Petitioners have the burden of
demonstrating their entitlement to any deductions claimed. Rule
142(a); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). A taxpayer must keep sufficient records to substantiate
claimed deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
In particular, to substantiate entitlement to a depreciation
deduction, the taxpayer must establish, among other things, the
property’s depreciable basis, by showing the property’s cost, its
useful life, and the previously allowable depreciation. See,
e.g., Cluck v. Commissioner, 105 T.C. 324, 337 (1995). The record
contains no credible evidence establishing Sparkman’s entitlement
to the claimed HEH losses; consequently, we sustain respondent’s
determination that he is not entitled to the claimed HEH losses
for the years at issue.
V. Additional Deductions Claimed by Sparkman
On brief, petitioners contend that if Mercury Solar PTO is
disregarded for tax purposes, or if Sparkman is found not to be
entitled to his claimed HEH losses, then he should be permitted to
amend his individual income tax returns for the years at issue to
claim additional charitable deductions and mortgage interest
deductions. Petitioners’ brief does not specify what the amounts
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