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provide the Court with records of any sites visited, dates or
hours worked, or mileage traveled by his father in order to
establish the validity of the $30,000 consulting fee payment and
the corresponding expense to petitioner. The personal check
petitioner issued to his father is the only documentary evidence
provided to substantiate the deduction. The $30,000 check drawn
from petitioner’s Bank of America account fails to substantiate
the purpose of the check. Due to the heightened scrutiny we give
to intrafamily transactions, the testimony of petitioner’s father
coupled with the $30,000 check paid from petitioner’s personal
account are insufficient to establish that petitioner and
petitioner’s father conducted business activities together during
1996. Accordingly, petitioner has failed to substantiate the
purpose of the $30,000 payment.
Petitioner has shown neither that he conducted a real estate
investment business during 1996 nor that he is entitled to an
ordinary and necessary business deduction for the $30,000 related
to efforts petitioner’s father allegedly made in an attempt to
secure potential real estate investment opportunities for Asian
investors. Petitioner did not appear or testify at trial. See
Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165
(1946), affd. 162 F.2d 513 (10th Cir. 1947). As we do not need
to accept testimony of an interested party without corroborating
evidence, the testimony of petitioner’s father, along with the
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