William Barry Blythe and Cheryl Lynn Blythe - Page 9




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          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.                              

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