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carryforward. Meissner v. Commissioner, T.C. Memo. 1995-191;
Aazami v. Commissioner, T.C. Memo. 1993-436.
Petitioner refused to testify about the capital loss
carryforwards. Aside from her 1997 and 1998 tax returns,
petitioner offered little evidence to substantiate these losses.
An entry on a tax return does not establish the existence of a
loss. Halle v. Commissioner, 7 T.C. 245, 250 (1946), affd. 175
F.2d 500 (2d Cir. 1949); Foust v. Commissioner, T.C. Memo. 1995-
481. Respondent’s determination that petitioner is not entitled
to a deduction for capital loss carryforwards is sustained.
3. Rental Expenses
Section 212 provides a deduction for all ordinary and
necessary expenses paid or incurred with respect to management,
conservation, and maintenance of property held for production of
income, including real property. Sec. 1.212-1(h), Income Tax
Regs. Generally, a taxpayer must establish that deductions taken
pursuant to section 212 are ordinary and necessary expenses and
must maintain records sufficient to substantiate the amounts of
the deductions claimed. Sec. 6001; Meneguzzo v. Commissioner, 43
T.C. 824, 831-832 (1965); sec. 1.6001-1(a), (e), Income Tax Regs.
Respondent disallowed $7,520 of the expenses pertaining to
Primera and $7,744 of the expenses pertaining to Otium. At
trial, petitioner refused to provide any information at all
pertaining to these expenses. The Court sustains respondent's
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