Padgett Coventry Price - Page 29

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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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