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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.
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