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II. Allied Electric Business Deductions
A. Net Operating Loss Carryforwards
Petitioner contends, but failed to establish, that his 1994
income is offset by net operating losses. See Jones v.
Commissioner, 25 T.C. 1100, 1104 (1956)(holding that a taxpayer
must prove the amount of the net operating loss carryforward
deductions claimed and that his gross income in other years did
not offset those losses), revd. and remanded on other grounds 259
F.2d 300 (5th Cir. 1958). Petitioner’s documentary evidence
consisted of his tax returns and a worksheet with figures
differing from those on the returns. See Wilkinson v.
Commissioner, 71 T.C. 633, 639 (1979)(holding that tax returns
alone do not establish a taxpayer’s entitlement to claimed
deductions). Respondent concedes petitioner had eligible net
operating losses of $15,546, $3,577, $35,791, and $9,573 in 1982,
1989, 1991, and 1992, respectively. These losses were absorbed
by income in carryback and carryover years prior to 1994. See
sec. 172(b)(stating that net operating losses must be carried
back 3 years and the remaining portion carried forward 15 years).
Accordingly, petitioner does not have a net operating loss
carryforward in 1994.
B. Additional Business Depreciation
Petitioner failed to establish that the Lincoln Town Car was
used for business purposes. We conclude, however, that the
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