A. Wayne and Linda D. Doudney - Page 7

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          taxpayer has produced credible evidence relating to the tax                 
          liability at issue and has met his substantiation requirements,             
          maintained required records, and cooperated with the Secretary’s            
          reasonable requests for documents, witnesses, and meetings.                 
               Petitioners have produced no credible evidence supporting              
          their disputed capital transactions or their disallowed                     
          deductions and exemption.  Petitioners produced only summary                
          “Affidavits of Fact” that declared the accuracy of each line of             
          petitioners’ amended returns.  Petitioners made no effort to                
          provide respondent with any receipts, canceled checks, copies of            
          invoices, or other records to substantiate the items claimed on             
          their amended returns that respondent disallowed.  Because                  
          petitioners failed both to cooperate with respondent and to                 
          substantiate their losses and deductions, we conclude that                  
          petitioners did not satisfy the requirements of section 7491(a)             
          and that the burden of proof remains with petitioners on all                
          issues.                                                                     
          Capital Transactions                                                        
               Section 1001(c) requires all gains or losses on the sale of            
          capital assets to be reported on the taxpayer’s return, unless a            
          separate Code section provides otherwise.  Although petitioners             
          provided some documentation during the examination to                       
          substantiate a small capital loss for 1999, petitioners did not             
          substantiate the remaining losses claimed.  At trial, petitioners           






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