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the management, conservation, or maintenance of property held for
the production of income under section 212. We further find on
that record that petitioner has failed to carry his burden of
establishing that he is entitled under section 212 to deduct any
of those claimed expenses.23
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
23Assuming arguendo that we had found that petitioner had
satisfied his burden of showing that he is entitled under sec.
212 to deduct the expenses at issue, on the record before us, we
find that petitioner has failed to satisfy his burden of showing
that he complies with the substantiation requirements of sec.
274(d)(1) and (2) and the regulations thereunder with respect to
those expenses.
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