- 22 - 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 thePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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