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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.
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Last modified: May 25, 2011