Charles Vernon Roberts - Page 20

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          California return or support his assertion that the California              
          return was correct when filed.  The absence of documentary                  
          evidence was not explained by petitioner.  The fact that the                
          California return was signed under penalty of perjury is not                
          sufficient to substantiate the deductions claimed on it.  See               
          Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979); Roberts v.              
          Commissioner, 62 T.C. 834, 836-837 (1974).  Thus, petitioner has            
          failed to substantiate the claimed deductions and, therefore, is            
          not entitled to the claimed itemized deductions.                            
               The record does contain a copy of a real estate tax bill for           
          the Inglewood property for the fiscal year ending June 30, 1980.            
          That document reflects a property tax assessment of $235.52.                
          Moreover, in 1983, taxpayers were entitled to a deduction for               
          general sales tax, which, in the absence of substantiation of               
          actual expenditure, could be claimed based on tables promulgated            
          by respondent based upon reported income.  Also in 1983, itemized           
          deductions necessarily had to exceed the zero bracket amount in             
          order to be beneficial taxwise.  The zero bracket amount for 1983           
          for a married taxpayer filing single was $1,700.  The allowance             
          of any amount based on the 1980 real estate tax assessment for              
          the Inglewood property and an allowance for sales taxes would not           
          come anywhere near $1,700.  Accordingly, we deny petitioner's               








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