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expenses. Mr. Monson’s testimony related to 1980--a decade
before the years in issue and long before petitioner joined the
law firm--and Mr. Monson’s testimony was vague. Accordingly, we
sustain respondent’s determination on this issue.
C. Schedule E Loss
Respondent disallowed Schedule E losses petitioner claimed
relating to alleged rental real estate because petitioner failed
to substantiate the loss and petitioner’s son lived at the
property.
Taxpayers are required to maintain books and records
sufficient to establish the amount of their income and losses.
Sec. 6001; DiLeo v. Commissioner, 96 T.C. at 867. As we stated
supra, the Court is not required to accept petitioner’s
unsubstantiated testimony. See Wood v. Commissioner, supra at
605. We found petitioner’s testimony to be general, vague,
conclusory, and/or questionable in certain material respects.
Under the circumstances presented here, we are not required to,
and do not, rely on petitioner’s testimony to sustain her burden
of establishing error in respondent’s determinations. See Lerch
v. Commissioner, supra at 631-632; Geiger v. Commissioner, supra
at 689-690; Tokarski v. Commissioner, supra at 77. Accordingly,
we sustain respondent’s determination on this issue.
D. Alleged Embezzlement
Section 165(a) allows a deduction for any loss "sustained"
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