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third receipt did not describe the item purchased. None of the
amounts shown equaled the $350 claimed on the return. The shoes
reflected in the receipts and testimony would be adaptable to
personal use.
OPINION
The details of the claims made on the 2002 return, the
claims belatedly made as the case proceeded, and the quality of
evidence produced by petitioners are set forth in our findings of
fact because this case depends on the credibility of petitioners
and their documentation. Because petitioners did not retain
required records and did not introduce credible evidence with
respect to the disputed deductions, the burden of proof remains
with them. See sec. 7491(a). For the reasons set forth below,
we conclude that petitioners’ evidence is not reliable and that
they are not entitled to any deductions beyond those conceded by
respondent.
With respect to the medical expenses in issue, besides
introducing incomplete and illegible documents, Ms. Jackson
presented vague and uncertain testimony as to the date certain
medical expenses were paid, the nature of the treatment, and the
family member who received treatment. She belatedly attempted to
reconstruct mileage expenses for travel to medical providers, but
the reconstruction is unreliable because there are no reliable
records supporting the trips alleged. We cannot conclude on this
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