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Instead of attempting to substantiate the disallowed
deductions through third-party or duplicate records (e.g.,
statements from banks, credit card companies, local property tax
records, etc.), petitioner produced various documents that he
claims remained in his possession after the search. These
documents include an unsigned blank check and deposit slip from a
“business account”, illegible copies of credit card receipts,
automobile repair bills, several bank statements for a joint
checking account, a notice advising petitioner and his spouse
that their automobile insurance had expired and another notice
indicating that the insurance had been reinstated, a notice that
petitioner’s real estate taxes for 1991 and 1992 were delinquent,
a bill for a newspaper classified advertisement, a deed, a copy
of a check made payable to Fleet Funding Assumption Department
which appears not to have been negotiated, copies of mortgage
statements, and copies of utility bills. When describing these
documents at trial, petitioner acknowledged that some of them had
nothing to do with deductions claimed on his 1988 return. Only
some of the documents introduced into evidence by petitioner
relate to 1988. According to petitioner, these documents were
not seized along with his other records for that year because the
agents conducting the search “missed” them. Furthermore, to the
extent a document seems to relate to a deduction claimed by
petitioner, it is equally plausible that the document relates to
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