- 7 - bears the burden of proving entitlement to any deduction claimed. See Deputy v. du Pont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Moreover, a taxpayer is required to maintain records that are sufficient to substantiate his deductions. See sec. 6001. At trial, petitioner proffered a photocopy of a cashier's check dated August 6, 1993, made payable to First Federal Savings Bank in the amount of $10,368.49, as evidence of petitioners' payment of interest. However, petitioners provided no evidence, other than petitioner's vague and uncertain testimony, of the amount of the interest and principal portions of the payment or of the purpose of the loan. Accordingly, petitioners have not met their burden of proving entitlement to deduct any expense for interest in an amount greater than that allowed by respondent. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011