- 8 - of principal and interest. The signature on the check is illegible. Stamped on the face of petitioner's check is the notation, dated October 2, 1991, that the check was returned due to "Endorsement Irregular/ ENDORSEMENT MISSING". On December 27, 1991, through business check No. 1983, petitioner paid $1,000 to the order of Steven Hirahara. The check was from "Les Hirahara - Realtor". The memo portion of this check states that it is for the payment of interest. The evidence offered is insufficient to show petitioner's entitlement to the interest deduction. The payment to Nuuanu Streamside, Inc., was not made because the check was returned due to an irregularity. The only evidence pertaining to the interest deduction is petitioner's unsubstantiated testimony. He did not proffer the testimony of a representative from Nuuanu Streamside, Inc., nor his brother's testimony (Steven Hirahara) in an attempt to corroborate petitioner's stated reasons for the payments. Moreover, petitioner did not document the purported loan amounts, the amounts of interest payable, or the terms of payment. The notations on the submitted checks are insufficient. Petitioner's failure to provide corroborative evidence presumably in his control weighs against him. Tokarski v. Commissioner, 87 T.C. 74 (1986). Respondent is sustained on this issue. B. Depreciation Expense Deduction Petitioner claimed a deduction for depreciation on Schedule C of his 1991 income tax return with respect to assets that werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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