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received under the policy. On May 18, 1995, petitioner filed
amended Federal income tax returns on which she reported income
of $60,000 and $90,000, respectively, for 1992 and 1993. On her
1993 amended return, petitioner deducted $150,000 in business
expenses. This resulted in a $60,000 net operating loss which
petitioner then carried back and applied against her 1992 gross
income. On July 31, 1996, respondent issued a notice of
deficiency to petitioner. Respondent determined that petitioner
was not entitled to deduct the claimed business expenses and was
liable for deficiencies in her Federal income tax, additions to
tax, and accuracy-related penalties.
Discussion
Petitioner contends that she should be allowed to offset the
income she received from the insurance proceeds by deducting
NHR's business expenses. Respondent contends that petitioner has
failed to establish that she is entitled to such a deduction. We
agree with respondent.
Petitioner did not present any evidence to establish that
she paid NHR's expenses. Moreover, even if she had presented
such evidence, petitioner has failed to cite, and we have not
found, any authority that would permit her to deduct NHR's
expenses on her personal return. See Rule 142(a); New Colonial
Ice Co. v. Helvering, 292 U.S. 435, 440 (1934) (stating that "a
taxpayer seeking a deduction must be able to point to an
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