Kondamodi S. Rao and B. Satyaveni Rao - Page 22

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          v. Helvering, 292 U.S. 435, 440 (1934).  Section 6001 requires              
          taxpayers to maintain adequate records from which their tax                 
          liability may be determined.  Petzoldt v. Commissioner, 92 T.C.             
          661, 686 (1989).                                                            
               Petitioners offered no evidence or argument concerning the             
          $10,105 of deductions taken for an undetermined rental activity.            
          We hold that petitioners have abandoned that portion of the                 
          substantiation issue.                                                       
               Petitioners have offered nothing other than vague testimony            
          by Dr. Rao to substantiate expenses other than interest,                    
          equipment lease payments, and depreciation.  We hold that these             
          other expenses are not substantiated.  "We know of no rule that             
          uncontradicted testimony must be accepted by a court finding the            
          facts, particularly where, as here, the testimony is given by               
          interested parties."  Wood v. Commissioner, 338 F.2d 602, 605               
          (9th Cir. 1964), affg. 41 T.C. 593 (1964).                                  
               Petitioners proved that they bought the medical center                 
          building in 1980 for $120,000.  Dr. Rao testified that in the               
          early 1980's he borrowed $70,000 from Columbia to make                      
          improvements to the medical center and $50,000 from Chase to                
          purchase equipment.  However, no invoices or canceled checks were           
          offered to substantiate any improvements or equipment purchases.            
          We do not know exactly what equipment was purchased, how much the           








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