- 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.
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