Creed J. Pearson - Page 7




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          respectively.  On the basis of third party information returns,             
          respondent also concedes that under section 163 petitioner is               
          entitled to Schedule A deductions for mortgage interest expenses            
          in the amounts of $22,000, $18,933, $17,909, and $16,661 for                
          taxable years 2000, 2001, 2002, and 2003, respectively.  We                 
          accept these concessions.  See Cohan v. Commissioner, 39 F.2d               
          540, 543-544 (2d Cir. 1930).                                                
               As to the remaining expenses, petitioner offered no evidence           
          that he actually incurred them or that he is entitled to a                  
          deduction for them, and therefore he has not met his burden of              
          proving that he is entitled to claim deductions for any expenses            
          to the extent that they exceed respondent’s concessions.                    
          Petitioner’s Audit Request                                                  
               Petitioner asks that we allow him to audit the Organization,           
          which is not a party to this case, and that he be able to pay his           
          taxes out of the proceeds of that audit.  There is no provision             
          in the Code that gives us the authority to allow one taxpayer to            
          audit another taxpayer in order to reduce his tax deficiency.               
          Therefore, we deny petitioner’s request.                                    
          Additions to Tax                                                            
               Section 6651(f) and (a)                                                
               Respondent asserts that petitioner is liable for an addition           
          to tax under section 6651(f) for each year in issue.  Section               
          6651(f) imposes a penalty of up to 75 percent of the amount of              







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