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trial, thus precluding any reasonable investigation of events
that occurred 4 years earlier. Petitioner’s testimony at trial
was vague and conclusory, and he attempted to add additional
details only in his answering brief, after respondent pointed out
the defects in his case. Although he claimed at trial that he
had no money to employ counsel or a collection agency to pursue
collection, he asserted in his posttrial brief that he had
employed counsel and a collection agency. There is no evidence
or even suggestion as to the dates on which collection efforts
were pursued. The statements contained in petitioner’s answering
brief, of course, cannot be considered as evidence. Rule 143(b).
His inconsistent assertions are, however, an indication of the
unreliability of his testimony at trial. In any event, none of
the belated submissions would cure the gaps in petitioner’s
evidence with respect to the bona fides of the alleged loans, the
capacity and intent of the alleged debtors, or the worthlessness
of the alleged debts during the same year in which they were
allegedly created. Petitioner’s claims are improbable, and we
cannot accept them. Geiger v. Commissioner, 440 F.2d 688, 689
(9th Cir. 1971), affg. T.C. Memo. 1969-159.
Investment Interest Expense
Section 163 allows a deduction for interest paid during the
taxable year. Section 163(d), however, limits the amount of the
investment interest that is deductible by individual taxpayers to
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