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$3,325, respectively. Michael Michoff, Sr., did not testify on
behalf of the Michoff, Srs. Beverly Michoff did not know in what
years the alleged casualty losses occurred. Beverly Michoff was
unsure whether the items for which casualty losses were claimed
were insured. The Michoff, Srs., did not provide any documentary
evidence to establish the alleged casualty losses claimed on the
1989 and 1990 income tax returns of the Michoff, Srs. The
Michoff, Srs., have the burden of proving that they are entitled
to the deduction. Smith v. Commissioner, 76 T.C. 459, 463
(1981). The Michoff, Srs., have failed to meet this burden.
Thus, respondent is sustained on this issue.
Christmas Tree Farm for the 1990 Tax Year
Respondent determined that the Michoff, Srs., improperly
claimed Schedule C deductions in the amount of $4,300 with regard
to a Christmas tree farm business. In their answers to
respondent's requests for admissions the Michoff, Srs., admit
that they were not entitled to claim any loss on the Christmas
tree farm during the years in issue. Additionally, the parties
have stipulated that the Michoff, Srs., claimed Schedule C
deductions, to which they were not entitled, pertaining to a
Christmas tree farm. The Michoff, Srs., never sold any trees
from the tree farm. On brief, the Michoff, Srs., contend that
they entered the tree farm business with the intent to make a
profit. “Petitioner has the burden of proof as to both the
deductibility and substantiation of her claimed business
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