- 5 - made by petitioner to himself. Furthermore, even if there had been a separate entity to which a loan could have been made, petitioner has not provided any reliable evidence of a loan. The alleged loan document provided by petitioner (which relates only to the alleged 1990 loan) is not reliable because it consists of one paragraph, does not require interest payments, does not require the repayment of principal at any time certain, and although it refers to a secured party does not provide security for the loan. Furthermore, petitioner’s testimony concerning David Killian, who signed the document as a witness, suggests that the document may have been signed at a later time and backdated to 1990. Petitioner also produced as evidence copies of two amended returns allegedly filed in 1993 for the taxable years 1990 and 1992. Attached to each return was a sheet of paper on which the amount of reported Schedule C income was divided into two categories: “1099 Farmers” and “Loan Kevin”. The total Schedule C income was $57,504 in 1990 and $162,650 in 1992. The loan income was listed as $31,712 in 1990, and $55,293 in 1992. It is unclear why these returns were to be filed because no changes in taxable income or tax liability were shown on them. In any event, these are mere uncorroborated assertions by petitioner and are not reliable evidence. Second, assuming arguendo that a loan had in fact been made, the repayment of one’s own debt generally is not deductible.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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