David W. Chiu - Page 14

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            expenditures and a failure to demonstrate that he met the                                    
            requirements of section 217.11                                                               
            Real Estate Taxes                                                                            
                  Petitioner claimed real estate taxes of $1,130 on Schedule A                           
            of his 1990 return, which respondent disallowed for failure to                               
            substantiate.  Section 164(a)(1) allows a deduction for State and                            
            local real property taxes paid or accrued within the taxable                                 
            year.  Petitioner has failed to produce any evidence to show that                            
            he paid the real property taxes claimed on his return.  In fact,                             
            petitioner indicated in his testimony that he was uncertain                                  
            whether, and to what extent, he or his ex-wife paid the 1990 real                            
            estate taxes.  We conclude that petitioner has failed to                                     
            substantiate the payment of real estate taxes in 1990 and is                                 
            therefore not entitled to any deduction for them.                                            
            Mortgage Interest                                                                            
                  Petitioner claimed a deduction for mortgage interest on                                
            Schedule A of his 1990 return, which respondent challenges on the                            
            grounds that petitioner has failed to substantiate the payment of                            
            any mortgage interest or to provide sufficient evidence from                                 
            which a reasonable estimate could be made.                                                   



                  11With respect to the $500 in expenses claimed with respect                            
            to the move from San Francisco to Los Angeles, petitioner has not                            
            shown that he commenced new employment in Los Angeles or that                                
            such employment continued for the minimum periods required under                             
            sec. 217(c)(2).                                                                              




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