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documents into evidence, we find that those documents do not show
that respondent conceded at the meeting in question that peti-
tioner substantiated the total amounts of expenses relating to
the Sanchez Street property that were paid during 1991 and 1992,
respectively. We further find that petitioner’s documents do not
establish such amounts, and consequently we reject petitioner’s
position on brief that those documents substantiate the total
amount of expenses relating to the Sanchez Street property that
were paid during 1991 and 1992, respectively. Although peti-
tioner’s documents establish that certain amounts were paid
during 1991 and 1992, respectively, and although it appears that
some of those amounts were paid with respect to the Sanchez
Street property, we find that petitioner’s documents do not
establish (1) that any of the amounts reflected in those docu-
ments were paid by petitioner103 and (2) that all of those amounts
constitute deductible expenses, as opposed to expenditures (e.g.,
capital improvements) that must be capitalized.104
103In this connection, all of the canceled checks that are
included in petitioner’s documents were drawn on accounts owned
by persons other than petitioner and were signed by individuals
other than petitioner. On the instant record, we find that
petitioner has failed to carry his burden of showing that any of
his funds were deposited during 1991 and 1992 into the bank
accounts on which those checks were drawn or that he otherwise
provided during those years the funds to pay certain of any
expenditures relating to the Sanchez Street property.
104In support of his position that he is entitled to deduct
for 1991 and 1992 the respective claimed Schedule E expenses
relating to the Sanchez Street property, petitioner relies, inter
alia, on Mr. Dubrovsky’s testimony that petitioner was liable for
his share of the expenses on the Sanchez Street property. We are
not required to, and we shall not, rely on Mr. Dubrovsky’s
testimony. In this connection, Mr. Dubrovsky gave conflicting
(continued...)
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