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the heightened substantiation requirements of section 274, where
applicable, or of enabling us to make any reasonable estimate
under Cohan v. Commissioner, supra. Accordingly, we reject
petitioner’s claim on brief that evidence of substantiation was
provided to respondent prior to January of 2002.
We likewise give little weight to petitioner’s statement on
brief that evidence of substantiation tendered after January of
2002 would not have been considered by respondent. Petitioner
has at no time shown either an ability or a willingness to
provide additional relevant material. He neither testified at
trial nor offered any pertinent substantiating exhibits.
Moreover, the only other information tendered to the Court,
through petitioner’s tardy motion to reopen the record, would,
even if accepted and as previously explained, have failed to
demonstrate entitlement to any further deductions. The materials
do not tie any specific expense to a particular for-profit
business or investment endeavor.
With respect to petitioner’s reliance at trial on having
filed returns signed under penalty of perjury, petitioner
apparently reiterates this position on brief, as follows:
Petitioner duly filed his 1998 and 1999 income tax
returns which were signed under penalty of perjury by
petitioner, timely filed pursuant to 26 United States
Code � 7502 through the United States mails, and
received in evidence; respondent failed to demonstrate
that any request for substantiation of the deductions
thereupon taken was made of petitioner. The deductions
were therein not properly disallowed as
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