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taxpayer bears the burden of proving that he or she is entitled
to any deduction claimed. Rule 142(a); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934). This includes the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976).
In support of the items remaining in dispute with respect to
the California property, petitioner introduced an invoice titled
"Trial Balance". The invoice, dated January 27, 1989, and
created for petitioner by Inland, lists income and expenses
attributable to the California property. Petitioner testified
that several of the items on the invoice are incorrect, and based
on the lack of available receipts or other supporting documents,
we are unable to determine whether the expenses were actually
paid, and, if so, in which year (1988 or 1989).
With respect to the Charleston property, petitioner offered
no receipts, travel logs, or other documentation to substantiate
the items still in dispute, other than handwritten schedules and
lists of expenses prepared for trial. Despite the fact that
petitioners filed amended returns as late as May 1994, 1 month
before trial, they were unable to provide any credible evidence
to support the deductions claimed. Furthermore, several of the
items in dispute, if in fact purchased, would be in the nature of
improvements with an expected life greater than 1 year, and the
costs associated therewith must be capitalized and depreciated
pursuant to statutorily prescribed limits. The testimony of
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