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section 7491(a) that petitioner introduce credible evidence,
substantiate his deductions, and cooperate with respondent. See
Higbee v. Commissioner, 116 T.C. 438, 445 (2001) (document
summarizing amounts allegedly owed and paid as business expenses
insufficient to shift burden); see also Davis v. Commissioner,
T.C. Memo. 2005-160 (taxpayer’s vague, conclusory, and general
testimony insufficient to shift burden under section 7491(a)).
The affidavit simply repeats the listing of deductions on the
Schedule C and affirms that they are correct. The affidavit does
not describe petitioner’s trucking activity or explain the types
of expenses generated by the activity. The affidavit does not
contain any credible evidence that the deductions in question
were actually paid or that the expenses were ordinary and
necessary expenses and were reasonable in amount as required by
section 162. The affidavit also contains no information to
establish that requirements of other applicable Code sections,
such as section 274, were satisfied.
We conclude that the requirements of section 7491(a) are not
satisfied by the affidavit on which petitioner relies.
Consequently, petitioner bears the burden of proving that he paid
deductible expenses during 2000 in connection with his trucking
activity.
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