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Summary and Conclusions
Petitioner blames his present situation on the U.S.
Government, the Justos, his former wife, his former landlord, and
unidentified others. We are satisfied that petitioner’s
predicament is of his own making. Respondent has, by the receipt
books in evidence and petitioner’s testimony, presented
substantive evidence that petitioner received unreported income.
See Rapp v. Commissioner, 774 F.2d 932, 935 (9th Cir. 1985);
Petzoldt v. Commissioner, 92 T.C. 661, 687-690 (1989); Tokarski
v. Commissioner, 87 T.C. 74 (1986). Petitioner has shown no
error in respondent’s corrected schedules of income set forth in
respondent’s opening brief. Petitioner has not identified any
deductions to which he is entitled beyond those conceded by
respondent based on the records in evidence. Petitioner’s burden
with respect to deductions is well established. See, e.g.,
Rockwell v. Commissioner, 512 F.2d 882 (9th Cir. 1975), affg.
T.C. Memo. 1972-133. As explained above, we do not believe
petitioner’s claims that respondent is responsible for his
inability to substantiate deductions. Even if the records had
been lost or destroyed while in respondent’s hands, however,
petitioner would not be relieved of his burden with respect to
deductions. See Foster v. Commissioner, 756 F.2d 1430, 1439 (9th
Cir. 1985) (taxpayers’ “self-certification of their record-
keeping system is not a substitute for proof of their
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