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7491(a)(1) and (2)(A). Consequently, the burden of proof is not
placed on respondent. Because petitioners have failed to present
us with any credible evidence, they have not met their burden of
proof pursuant to Rule 142(a) to support their claimed
deductions. We therefore hold that petitioners are not entitled
to a deduction for charitable contributions in excess of the
$1,500 that respondent has already allowed.
C. Unreimbursed Employee Expenses and Schedule C
and E Expenses
Petitioners argue that they are entitled to a deduction of
$6,468.09 for unreimbursed employee expenses instead of the
$3,075 deduction returned on their Schedule A for 1996. Aside
from Mrs. Higbee’s self-serving testimony at trial that these
additional expenses related to her employment at a beauty salon,
petitioners have failed to provide us with sufficient and
credible evidence for us to rule in their favor.
Petitioners also claim additional Schedule C deductions of
$8,087.26 for 1996 and $8,590.48 for 1997 on account of amounts
allegedly owed and paid with regard to their failed beauty salon
business. Petitioners contend that they paid these amounts while
they arrived at those fair market values, we are unable to allow
such deductions. Further, petitioners have not produced any
other independent and credible evidence indicating that those
donations were actually made.
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