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Similarly, in Bukove v. Commissioner, T.C. Memo. 1991-76,
the taxpayer claimed investment tax credits attributable to
various partnership interests, some TEFRA and some non-TEFRA. We
stated:
To the extent that the claimed ITC is attributable
to one or more non-TEFRA partnerships, petitioner must
prove (1) the identity of the partnership through which
the ITC is claimed; (2) the identity, cost, and date
placed in service of any qualifying property; and (3)
whether the partnership used the property in a trade or
business. * * *
Petitioner introduced no evidence regarding the
source of the ITC’s, other than * * * [petitioner’s
return preparer’s] blanket assertion that they were
generated by Dickinson and NDL. Petitioner introduced
no evidence to establish what qualifying property was
acquired, that the property was ever placed in service,
or that the property was actually used in a trade or
business. No partnership records were presented and no
partnership personnel testified. Rather, petitioner’s
evidence consisted of vague testimony * * * [Id.]
With respect to the case at bar, the record is equally
bereft of evidence that could provide a factual underpinning of
the type demanded in Johnson v. Commissioner, supra, and Bukove
v. Commissioner, supra. Contrary to petitioners’ assertions, it
has long been held that statements made in tax returns do not
constitute proof of the transactions underlying the reported
figures. Seaboard Commercial Corp. v. Commissioner, 28 T.C.
1034, 1051 (1957); Halle v. Commissioner, 7 T.C. 245, 247, 249-
250 (1946), affd. 175 F.2d 500 (2d Cir. 1949). Accordingly, the
Schedule K-1 on which petitioners rely cannot be regarded as more
than an assertion of their claim. We also note that Mr. Aulisio
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