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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 were
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