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142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). A
taxpayer is required to maintain records sufficient to
substantiate deductions claimed on his tax return. Sec. 6001;
sec. 1.6001-1(a), Income Tax Regs. Moreover, a taxpayer who
claims a deduction bears the burden of substantiating the amount
and purpose of the item claimed. Hradesky v. Commissioner, 65
T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976); sec. 1.6001-1(a), Income Tax Regs.
To establish the amount of time petitioner spent on his
rental real estate activities, petitioners introduced a
spreadsheet summarizing the work activities he performed on a
daily basis for each of his three rental properties (daily work
log). The daily work log was not prepared contemporaneously as
petitioner performed each activity but was composed by
petitioners, purportedly from various receipts and documents, in
preparation for trial. Petitioners claim that they have the
underlying receipts and documents from which the spreadsheet was
prepared, but they did not think it was necessary to bring them
to Court for trial or to introduce them into evidence. In the
absence of any corroborative evidence, we do not consider the
daily work log persuasive.
Furthermore, the daily work log merely identifies tasks and
services performed by petitioner on a particular day. It does
not give any indication or approximation of how much time
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