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explained how the amounts paid under the car rental agreements
relate to the unemployment compensation litigation. We,
therefore, hold that petitioner has failed to establish that he
had any deductible expenses relating to the unemployment
compensation litigation other than the $4,396.75 conceded by
respondent.
In support of a claimed deduction for 1991 for taxes on his
car registration, petitioner submitted a copy of a canceled check
payable to Emmett Sanders in the amount of $32.37. In the notice
of deficiency, respondent did not disallow $20 of the deduction
claimed by petitioner for taxes on his car registration.
Petitioner has failed to show that the entire amount of the check
to Emmett Sanders was for taxes on his car registration. We
therefore uphold respondent's determination with respect to the
disallowance of a portion of the amount claimed by petitioner as
taxes on his car registration in 1991. The other taxes deducted
by petitioner in 1991 are utility taxes and tax on petitioner's
telephone bill. These items are nondeductible, and we sustain
respondent's disallowance of these claimed deductions. Sec. 164;
see Fife v. Commissioner, 73 T.C. 621 (1980).
Petitioner has offered no evidence to substantiate the
charitable contribution deduction claimed on Schedule A of his
1991 tax return. Since petitioner has not substantiated this
claimed deduction, we sustain respondent's disallowance of the
claimed deduction.
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