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to specific categories of expenses was vague and uninformative.
Moreover, petitioner made no effort to retrieve and produce in
this proceeding the records that he claims were turned over to
his accountant.
Simply put, petitioner has failed to present sufficient
evidence from which this Court could conclude that any farming
expenses were incurred and paid. In effect, petitioner has done
nothing more than offer his Federal income tax returns as proof
for the deductions here in dispute. Such evidence is hardly
sufficient to satisfy his burden of proof. See Roberts v.
Commissioner, 62 T.C. 834, 837 (1974). Accordingly, petitioner
is not entitled to Schedule F expense deductions in excess of
those allowed by respondent. Because of our holding, we need not
address whether the expenses claimed were ordinary and necessary
within the meaning of section 162.
The net operating loss carryovers that were claimed by
petitioners and disallowed by respondent for each year in issue
result from the losses petitioners claim to have incurred in the
farming activity. With respect to the year 1991, petitioners
conceded on their 1992 return that the 1991 net operating loss
deduction was miscalculated and that they were not entitled to a
net operating loss carryover in 1991. Our holding with respect
to deductions claimed on the Schedules F results in the
elimination of the net operating loss carryovers claimed in 1992
and 1993 that resulted from the claimed losses incurred from
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