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were incorrectly calculated, such partnership, trust, and
subchapter S losses are not allowable.
The only evidence in the record to support the deductions
claimed for the farm losses or expenses are petitioner's 1979 and
1980 returns and the general statements by Mr. Dutton, the return
preparer, that the farm showed a loss. We regard such evidence
as insufficient to sustain petitioner's burden of proof.
Moreover, one of petitioner's employees testified that the
records for the farm were included in the corporate records of
CDC through its subsidiary Caspian Farms. This is an indication
that the farm expenses were paid by CDC, and not by petitioner.
Because petitioner has failed to meet his burden of proving the
amounts of expenses or losses incurred or that they were his
expenses or losses, we hold that he is not entitled to the 1979
farm loss of $128,458 and the 1980 farm expenses of $249,204.
IX. Issue 13--Section 6653(b) Additions to Tax for Fraud
In the notice of deficiency covering the years 1972 through
1976 respondent determined additions to tax for fraud pursuant to
the provisions of section 6653(b) with respect to petitioner. In
an amendment to the answer filed herein, respondent asserted
increased additions to tax under section 6653(b) for the years
1973 through 1976. Section 6653(b), applicable for the years in
issue, provides that if any part of any underpayment of tax
required to be shown on a return is due to fraud, there shall be
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