- 132 -
requirements of section 274(d)(4).
On the record before us, we find that petitioner has failed
to carry his burden of establishing that he is entitled under
section 162(a) to deduct for 1991 and 1992 any of the telephone
expenses that he paid during those years.82
Claimed Bad Debt Deduction
Petitioner contends that he is entitled to deduct for 1992
the $20,000 payment that he made to Commonwealth Enterprises,
which he claims he made pursuant to an alleged loan guaranty.
According to petitioner, he guarantied a $20,000 loan from Mr.
Vulis to MP Electronics, and the $20,000 check dated December 18,
1992, which was payable to Commonwealth Enterprises, drawn on
petitioner’s UVW account, and signed by petitioner (UVW’s Decem-
ber 18, 1992 check), represented petitioner’s payment of that
loan pursuant to his guaranty. In support of his contentions,
petitioner relies on his self-serving testimony, on which we are
not required to, and we shall not, rely.83 On the instant re
82Although not altogether clear, it appears that petitioner
contends in the alternative to deducting the telephone expenses
at issue for 1991 and 1992 under sec. 162(a) that those expenses
are deductible under sec. 212. On the instant record, we find
that petitioner has failed to carry his burden of showing that
the respective telephone expenses that he paid during 1991 and
1992 are ordinary and necessary expenses paid during those years
for the production or collection of income. On the record before
us, we find that petitioner has failed to carry his burden of
establishing that he is entitled under sec. 212 to deduct for
1991 and 1992 any of the telephone expenses that he paid during
those years.
83Petitioner failed to offer into evidence any credible
documentary evidence to establish that Mr. Vulis made a loan to
(continued...)
Page: Previous 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 NextLast modified: May 25, 2011