- 31 - HEH returns (prepared, signed, and filed by Sparkman less than 3 weeks before trial) and attachments thereto, and Sparkman’s returns for the years at issue. We need not accept these figures, and we decline to do so. Petitioners have the burden of demonstrating their entitlement to any deductions claimed. Rule 142(a); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). A taxpayer must keep sufficient records to substantiate claimed deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. In particular, to substantiate entitlement to a depreciation deduction, the taxpayer must establish, among other things, the property’s depreciable basis, by showing the property’s cost, its useful life, and the previously allowable depreciation. See, e.g., Cluck v. Commissioner, 105 T.C. 324, 337 (1995). The record contains no credible evidence establishing Sparkman’s entitlement to the claimed HEH losses; consequently, we sustain respondent’s determination that he is not entitled to the claimed HEH losses for the years at issue. V. Additional Deductions Claimed by Sparkman On brief, petitioners contend that if Mercury Solar PTO is disregarded for tax purposes, or if Sparkman is found not to be entitled to his claimed HEH losses, then he should be permitted to amend his individual income tax returns for the years at issue to claim additional charitable deductions and mortgage interest deductions. Petitioners’ brief does not specify what the amountsPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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