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related to the $50,000 loan. Petitioner did not contest
respondent's disallowance of the $3,000 capital loss.
Accordingly, we sustain respondent's determinations.
2. Deductions for Rental and Other Expenses
Respondent denied, for lack of substantiation, petitioner's
deductions for state and local income taxes, unreimbursed
employee expenses, and expenses relating to rental property.
Although petitioner's testimony established that he owned rental
property and incurred expenses relating to this property, he
failed to substantiate, or provide any reasonable basis for us to
estimate, these expenses. Petitioner failed to meet his burden
of substantiating the remainder of his deductions. See Hradesky
v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Accordingly, we sustain respondent's
determination.
3. Addition to Tax for Failure To File a Timely Return
Respondent determined, pursuant to section 6651(a), a
$4,875 addition to tax for petitioner's failure to file in a
timely manner a 1991 Federal income tax return. Petitioner's
1991 return was filed on October 9, 1994. Petitioner did not
contest respondent's determination, yet respondent concedes that
he overstated the addition to tax by $1,625 in the notice of
deficiency. Accordingly, petitioner is liable for a $3,250
addition to tax.
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