- 9 - 79, 84 (1992). Petitioners attempted to satisfy that burden through Mr. Blythe's testimony as well as certain limited docu- mentary evidence which related only to the vehicle expense and depreciation deductions that they are seeking. We found Mr. Blythe's testimony about the deductions at issue to be general, conclusory, vague, and/or questionable. We found the limited documentary evidence to suffer from inadequacies that are similar to those that we found in Mr. Blythe's testimony. Suffice it to say that we consider the document which petitioners claim is a log of the miles that they drove during 1994 in their activity involving the ten parcels in question and which is the foundation for petitioners' claim to the vehicle expense deductions at issue to be suspect. The one-page document in the record relating to the depreciation deductions claimed with respect to seven of the ten parcels merely sets forth petitioners' position as to, inter alia, the date on which each such parcel was placed in service, the basis that petitioners claim they had in each such parcel for purposes of computing a depreciation deduction for 1994, and the amount of depreciation to which they contend they are entitled for each of those seven parcels. However, there is no evidence in the record establishing the correctness of petitioners' position as to each of those matters. For example, petitioners have not established that they had a basis in any of the parcels in question on which a depreciation deduction could be calcu- lated, let alone how any such basis should be allocated between nondepreciable land and depreciable buildings.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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