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some basis upon which an estimate can be made. Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985).
In this case, there is no basis upon which an estimate can
be made. Petitioner had 14 real estate properties during the
taxable years in issue. Petitioner had no books and records, or
any evidence of the expenditures in issue. For trial, petitioner
had no reconstructed records to support his claimed additional
deductions on the amended returns. Petitioner said his wife was
saddened over the death of her son, which is understandable.
Petitioner claims this made her so upset that she selectively
destroyed all the financial records around the time for preparing
the 1996 return, again around the time for preparing the 1997
return, and again after petitioner reconstructed records to
prepare the amended returns. As we noted, petitioner’s wife
signed the amended returns. It is not believable that she would
destroy business records pertaining to her own returns on the
convenient occasions mentioned by petitioner.
We are not required to accept petitioner’s generalized
statements and decline to do so here without supporting evidence.
Geiger v. Commissioner, 440 F.2d 688 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159. We also are not required to accept
the self-serving statements of petitioner as correct. Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986). On this record, we
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