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in a chapter 13 bankruptcy proceeding.5 In support, petitioners
submitted to the Court a document entitled “Debtor Receipts and
Disbursements Summary” which provides general information about
the deposits made by petitioners with the trustee of the
bankruptcy estate and the disbursements to creditors by the
trustee. As to the bankruptcy-related expenses claimed,
petitioners have failed to provide us with sufficient credible
evidence that petitioners had outstanding business debts which
were paid while in bankruptcy. Further, petitioners have failed
to explain the origin of these expenses in sufficient detail for
us to find that these expenses would be allowable for the tax
years in issue. Petitioners have failed to meet the
substantiation and record-keeping requirements of section
7491(a). The burden of proof therefore is not placed on
respondent. Finally, we conclude that petitioners have not met
their burden of proof to support the claimed deductions, and
therefore we sustain respondent’s determination as to this issue.
See Rule 142(a).
Petitioners also claim additional Schedule E deductions with
regard to their rental activities for repairs ($5,976.31 for 1996
and $2,080 for 1997), legal expenses ($5,217 for 1996),
automobile expenses ($475.64 for 1996), and insurance ($139 for
5 The claimed deduction of $8,087.26 for 1996 encompasses
the $1,920 still in dispute with regard to respondent’s
deficiency determination.
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