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It suffices that petitioner failed to produce any evidence
in this proceeding to support his claims of unreported losses for
any of the years in issue. See Rule 149(b). Petitioner failed
to comply with the Court’s orders compelling him to respond
properly to respondent’s requests for admissions and to
respondent’s discovery requests relating to his claims of
unreported losses. At trial, petitioner had no evidence to
present to show his entitlement to additional deductions. As in
Smith v. Commissioner, T.C. Memo. 2002-59, in which we recently
sustained the Commissioner’s determination to proceed with
collection, “petitioner did not provide at trial any evidence, in
the form of either testimony or documentation, to support his
claim to any additional deduction.” In attempted aid of his
effort to compel respondent to help petitioner uncover evidence
that would substantiate his claims, petitioner has instead made
unsubstantiated assertions that his alleged losses were caused by
a conspiracy in which respondent was a participant.
Taxpayers who dispute the Commissioner’s disallowance of
deductions claimed on their returns must show that they satisfied
the specific statutory requirements entitling them to the claimed
deductions. New Colonial Ice Co. v. Helvering, 292 U.S. 435
(1934); Davis v. Commissioner, 81 T.C. 806, 815 (1983), affd.
without published opinion 767 F.2d 931 (9th Cir. 1985). While
the Court may estimate the amount of allowable deductions where a
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