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bills, electric bills, and other living expenses. After trial,
the record was reopened and petitioner submitted a document
showing real estate tax expenses of $1,920.16 and mortgage
interest expense of $215.77.
We find that petitioner did not prove that any of the
claimed Schedule A deductions pertaining to his co-op were
attributable to the management of his rental property.
Unfortunately for petitioner, his personal expenses incurred in
connection with his co-op, where he resided, are nondeductible
personal living expenses. Sec. 262(a). We do not address the
restrictions under section 280A because this section was not
raised at trial. Petitioner would be well advised to consult a
United States tax expert before filing future nonresident
returns.
On this record, we have no choice but to conclude that
petitioner has not established his entitlement to the claimed
Schedule A deductions. Accordingly, we sustain respondent’s
determination on this issue.
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a tax return, unless the taxpayer established that
failure to do so is due to reasonable cause and not willful
neglect. The taxpayer must prove both reasonable cause and lack
of willful neglect. Crocker v. Commissioner, 92 T.C. 899, 912
(1989). “Reasonable cause” requires the taxpayer to demonstrate
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