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less than credible and his attitude regarding compliance with the
Internal Revenue Code and the regulations and the Tax Court Rules
of Practice and Procedure to be, at best, cavalier. Therefore,
we find no grounds upon which we may properly estimate an
allowable deduction in excess of the amount allowed by
respondent.
We next consider petitioner's deduction for monthly rental
payments for his office space in the aggregate amount of $6,420.
Immediately prior to trial, respondent conceded that four
payments for rent for January through April, totaling $2,140,
were allowable.
Petitioner was unable to locate a canceled check for the
rent payment he allegedly made in May, and was also unable to
produce receipts of money orders he allegedly purchased to pay
his rent from June through September. For the remainder of the
year, petitioner presented the following carbon copies of checks
written:
Date Check No. Amount Payee
10/10/96 335 $535 Dr. Cantrell
11/10/96 338 535 East Dallas Veterinary
12/9/96 406 535 Unknown1
1 Petitioner withdrew several exhibits during the trial for
the purpose of making copies and was informed by the Court
of his responsibility to return the copies for inclusion in
the record. To date, petitioner has failed to return the
documents.
There is no evidence in the record that the checks were, in fact,
issued to the payees or negotiated at all. Moreover, respondent
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