- 27 - 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 asPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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