Ahsan Mohiuddin - Page 16

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          establish that petitioner made mortgage payments and do not prove           
          that petitioner provided over half the support for his mother               
          during the years 1990 and 1991.  The mortgage documents fail to             
          satisfy petitioner's burden of proving that his mother was his              
          dependent during the years 1990 and 1991.  We sustain                       
          respondent's disallowance of petitioner's claimed dependency                
          exemption for his mother in both 1990 and 1991.                             
               The only documents offered by petitioner for the taxable               
          year 1990 in support of his claimed Schedule A itemized                     
          deductions relate to his claimed casualty loss and his claimed              
          moving expense deductions.  As evidence of his claimed casualty             
          loss, petitioner has submitted an affidavit.  As evidence of his            
          claimed moving expenses, petitioner has submitted 2 car rental              
          agreements and a hotel receipt.5                                            
               Section 165(h) provides limits set forth therein for the               
          deduction of personal casualty losses.  Under section 1.165-                
          7(b)(1), Income Tax Regs., the amount of loss to be taken into              
          account shall be the lesser of:  (1) The amount that is equal to            


          5  At the conclusion of the trial, the Court requested that                 
          respondent construct a list of each item which petitioner                   
          introduced into evidence in this case and state whether                     
          respondent agreed that the item represented an allowable                    
          deduction and whether that item corresponded to petitioner's                
          Schedule A or C claimed deductions for that particular year.  The           
          Court also instructed petitioner to list the exhibits in the                
          record and indicate specifically what each item is alleged to               
          prove.  While respondent followed the Court's instructions in               
          this regard, petitioner has failed to assist the Court in this              
          matter.                                                                     




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