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Charitable contributions 5,550 1,200
Mortgage interest 14,148 12,205
Petitioners failed to produce any convincing evidence to
substantiate the itemized deductions claimed on Schedules A of
their 1990 and 1991 returns in excess of the amounts allowed by
respondent. Accordingly, based on the record before us, we
sustain respondent's disallowance of Schedule A deductions except
as conceded.
2. Schedule C Deductions
On Schedule C of their 1990 Federal income tax return,
petitioners claimed deductions of $10,987. They claimed Schedule
C deductions for 1991 totaling $10,257. Respondent disallowed all
of these deductions on the basis of petitioners' failure to
substantiate.
At trial, petitioners failed to produce any convincing
evidence to substantiate the deductions claimed on Schedules C of
their 1990 and 1991 returns. Further, there is nothing in the
record before us that would provide us with a basis upon which an
estimate could be made. Accordingly, based on petitioners'
failure to satisfy their burden of proving respondent erred in
disallowing the claimed Schedule C deductions, we sustain
respondent's determination in this regard.
3. Dependency Exemptions
Petitioners have convinced us that they are entitled to
dependency exemptions for Kimberly (Mr. Walker's daughter) and
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