Russell A. Condello - Page 9

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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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