17
1991 and 1992, we could not tell whether these were expenses for
which respondent had previously allowed deductions.
Petitioner urges this Court to accept his tax returns as
prepared because he contends his deductions were reasonable.
However, it is not enough that petitioner asserts that his
deductions were reasonable; he must provide adequate proof. Sec.
6001; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976). Petitioner has not given us
an adequate basis to estimate his expenses under Vanicek v.
Commissioner, supra, or Cohan v. Commissioner, supra.
Petitioner argues that he may deduct as a Schedule C or E
expense $10,000 he paid as attorney's fees to Kolodny & Pressman
in connection with his purchase of the Riviera Apartments. We
disagree. He must capitalize those expenses. See INDOPCO, Inc.
v. Commissioner, supra.
We conclude that petitioner may not deduct more in Schedules
C and E expenses than respondent allowed for 1991 and 1992.
At trial, petitioner testified that he could not remember
why he deducted $19,865 as investment interest on Schedule A of
his 1992 return. We sustain respondent's disallowance of
petitioner's deduction for investment interest.
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