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from Dr. Kay was for expenses due under a term of Dr. Kay's
employment contract. On brief, petitioner did not make this
argument and apparently abandoned this position. Even if this
position were not abandoned, petitioner has not produced any
reliable evidence in support of his claim. Furthermore, Dr. Kay
testified credibly that she never shared in the net profits and
that her salary remained at a certain dollar amount per day.
Petitioner has not offered any credible evidence to disprove
respondent's determination that he received income from funds
paid by Dr. Kay. Petitioner's changing factual contentions
suggest that he has little regard for the truth. Thus,
respondent's determination will be sustained.
Equipment Depreciation
Respondent determined that petitioner is not entitled to
depreciation deductions claimed on medical/dental equipment and a
used neon sign. Petitioner bears the burden of establishing that
he is entitled to the claimed deductions. Rule 142(a); INDOPCO
v. Commissioner, 503 U.S. 79, 84 (1992); Rockwell v.
Commissioner, 512 F.2d 882, 886 (9th Cir. 1975), affg. T.C. Memo.
1972-133. This includes substantiating the amount of the item
claimed. Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd.
per curiam 540 F.2d 821 (5th Cir. 1976).
"Section 167(a) provides that a reasonable allowance for the
exhaustion, wear and tear, and obsolescence of property used in
the trade or business or of property held by the taxpayer for the
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