- 7 - for the requirement that he maintain books and records. Mills v. Commissioner, supra at 749; Harper v. Commissioner, 54 T.C. 1121, 1129 (1970). Second, respondent reduced petitioner's income attributable to the sale of certain securities by the amount of petitioner's verifiable basis in those securities. With respect to the sale of other securities, respondent included all the proceeds in petitioner's income because no information was provided by petitioner regarding his basis. Petitioner bears the burden of demonstrating that he is entitled to a basis in the securities in excess of that determined by respondent. Rule 142(a); Burnet v. Houston, 283 U.S. 223, 227-228 (1931). Section 1012 provides that the basis of property shall be the cost of such property. Under the circumstances present here, "cost", for purposes of the Code, means the amount paid by petitioner. Detroit Edison Co. v. Commissioner, 319 U.S. 98, 102 (1943); Borg v. Commissioner, 50 T.C. 257, 263 (1968). Petitioner did not provide respondent with any evidence regarding the cost to him of any of the sold securities. We find that petitioner has not met his burden of proving that he paid any amount in excess of that determined by respondent. Third, petitioner asserts that the bank charges that are recorded on his bank statement should be allowed as deductions in respondent's calculation of income. Section 162 allows as a deduction all the ordinary and necessary business expenses paidPage: Previous 1 2 3 4 5 6 7 8 9 Next
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