Joel Hillman - Page 4

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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                   
          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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