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5. Itemized Expenses
Petitioner argues that he is entitled to deduct certain
itemized expenses (i.e., medical expenses, real estate taxes, and
home mortgage interest) in amounts greater than allowed by
respondent. In addition to his general burden of proof discussed
above, petitioner must prove his entitlement to any deduction,
e.g., by maintaining sufficient records to substantiate his
claimed deductions. New Colonial Ice Co. v. Helvering, 292 U.S.
435, 440 (1934); Lychuk v. Commissioner, 116 T.C. 374, 384
(2001); see also sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Petitioner has failed to carry his burden of proof. The record
does not establish that petitioner is entitled to deduct any
itemized expense in an amount greater than allowed by respondent.
Lobe v. Commissioner, T.C. Memo. 2001-204, and cases cited
therein.
6. Additions to Tax
a. Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failing to
file a return on or before the specified filing date unless it is
3(...continued)
to persuade us that the amounts listed on the balance sheet are
correct, we decline to find those amounts as facts. We also note
that petitioner has never filed a tax return for 1995 through
2000 and that the record does not establish his taxable income
for any of the nondocketed years. Petitioner, therefore, has
failed to establish that any basis that he may have acquired in
Only Kids’ stock and debt before the subject year was not reduced
to zero because of losses claimed in those earlier years.
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