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$1,166 for insurance on investments, and $20,370 for repairs and
depreciation. Written at the top of Schedule A was "ANDREW", in
reference to Hurricane Andrew. Respondent disallowed
petitioners' claimed miscellaneous deductions for 1991 for lack
of substantiation.
As noted, taxpayers are generally required to substantiate
claimed deductions and credits by maintaining the records needed
to establish the amount of such items. Sec. 6001; sec. 1.6001-
1(a), Income Tax Regs. Petitioners did not elaborate upon which
of the reported Schedule A expense deductions related to
Hurricane Andrew, although petitioner did testify that "labor"
expenses reported on line 21 of Schedule C for that year were for
repairs caused by Hurricane Andrew. Petitioners submitted
photocopies of hundreds of checks, whose payees included Southern
Bell, Reader's Digest, American Family Publishers, J.C. Penney
Insurance, Allstate Insurance, Shell, Exxon, Texaco, and "cash,"
among others. Most of the checks do not indicate what was
purchased or the purpose of the expenditure. When asked to
clarify the stock and insurance expenses, petitioner testified
only that the stock was purchased to create a "perpetual fund for
the maintenance of" their parents' graves. We find both the
photocopies of the checks and petitioner's testimony insufficient
to substantiate the Schedule A miscellaneous deductions claimed
for 1991. Respondent is sustained on this issue.
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