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$5,196 (reported) for 1992; and $12,412 and $6,113 (both
reported) for 1991. Petitioner argues that these amounts were
reported on the estate’s tax returns. We disagree. The last
return that the estate filed was for 1990. We conclude that all
of the interest income, both reported and unreported, was
includable in petitioner’s gross income for the respective years
in which received.
4. Deductions
Petitioner seeks deductions for a 1990 or 1991 capital loss,
attorney's fees in excess of the $150,000 allowed by the
respondent, amounts repaid to his Public Employees Retirement
System (PERS) account, amounts allegedly deducted from employee
compensation paid to him in an earlier year, and alimony
allegedly paid to his ex-wife, Verna Jo Banks. Petitioner has
not proved his entitlement to any of these deductions. See Rule
142(a).
As to the capital loss, the record does not support
petitioner’s claim that he is entitled to deduct such a loss in
either 1990 or 1991. The same is true as to the excess
attorney’s fees. The only evidence petitioner presented to
substantiate his claim to a deduction for attorney’s fees paid in
1990 (over and above the $150,000 mentioned above) was his
uncorroborated testimony that he paid $45,000 of the settlement
proceeds to another attorney in the lawsuits. We find that
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