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claimed $12,478 of deductions for his C.P.A. business.
Respondent allowed $755 of these deductions.
In order to substantiate these expenses, petitioner
submitted a voluminous exhibit at trial containing copies of
checks and receipts. The exhibit included receipts from
restaurants, checks written to individuals, an airplane ticket
stub, etc. Other than his uncorroborated testimony, petitioner
did not present any evidence showing how these checks and
receipts related to his C.P.A. business. As stated earlier, we
find petitioner's testimony general, vague, and conclusory. We
do not rely on petitioner's testimony to sustain his burden of
establishing error in respondent's determination. See Lerch v.
Commissioner, supra at 631-632; Tokarski v. Commissioner, supra
at 77. We conclude that petitioner is not entitled to any trade
or business deductions in excess of those allowed by respondent.
C. Schedule E Deductions
On his Schedule E, petitioner claimed numerous deductions
relating to a rental property that he owned prior to marriage
located at 5900 Oregon Trail Court. The deductions resulted in a
loss of $2,132. Respondent denied many of the deductions
petitioner claimed, including mortgage interest expense, property
taxes, and hazard insurance, and determined that petitioner had
income from the rental property.
Section 212 permits a deduction for all ordinary and
necessary expenses paid or incurred during the taxable year for
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