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1992 and 1993, respectively, which represents the excess of
petitioner's verified itemized deductions of $12,156 and $11,942,
respectively, over the standard deductions claimed by petitioner
for those years. Respondent concedes that during the Appeals
conference, respondent allowed itemized deductions in the total
amounts of $12,434 for 1992 and $12,273 for 1993. However, the
following itemized deductions were disallowed due to lack of
substantiation:
1992 1993
Safe deposit rental $ 119
Moving expenses 800
Charitable contributions $3,100 3,757
Casualty/theft loss 52,000
______ _______
Total $3,100 $56,676
On brief, petitioner mentioned without discussion the
additional itemized deductions issue, but did not address this
issue at trial. Accordingly, we conclude that petitioner has
conceded this issue. Petitioner is not entitled to any itemized
deductions other than those allowed by respondent.
Even though petitioner had not claimed rental expenses on
his 1992 and 1993 returns, at trial he raised the issue that he
was entitled to claim rental expenses as a lessor for those two
years. He admitted he rented the property for only two months in
1991. He presented no credible evidence of any expenses for 1992
and 1993. On this record, petitioner has failed to substantiate
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