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We are not required to accept the unsubstantiated testimony
of petitioner's husband, and we decline to do so. Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986). The summary schedules
provided by petitioner do not demonstrate her entitlement to the
claimed deductions. Petitioner neither called the accountant who
allegedly prepared the schedules to testify, nor offered any
documentation underlying the schedules. This dual failure gives
rise to the presumption that the evidence, if produced, would be
unfavorable. Wichita Terminal Elevator Co. v. Commissioner, 6
T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir. 1947).
Therefore, we hold that petitioner is not entitled to use the
claimed depreciation and amortization deductions in the
computation of her 1987 and 1988 NOL.
Issue 2. Addition to Tax--Failure To Timely File
Section 6651(a)(1) provides for an addition to tax for
failure to file a Federal income tax return by its due date
determined with regard to any extension of time for filing,
unless it is shown that such failure is due to reasonable cause
and not due to willful neglect. Calendar year individual
taxpayers must file their Federal income tax return by April 15
following the close of the calendar year. Sec. 6072(a). The
taxpayer bears the burden of proof on this issue. Rule 142(a).
To demonstrate that petitioner did not timely file her 1987
and 1988 returns, respondent introduced a Form 4340, Certificate
of Assessments and Payments, for both 1987 and 1988, indicating
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