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petitioner purportedly supplied half) was the approximate fair
rental value or an otherwise reasonable cost of the space rented.
Sixth, for essentially the same reasons, we are also not
persuaded that petitioner incurred the advertising expenses he
claims for each year. We would add only that petitioner
testified that his advertising expenditures were "over a thousand
dollars a month" and yet only approximately $2,000 was claimed in
each of the 2 years in issue. Thus, his testimony bears no
rational relationship to the claimed expenses. In his testimony,
petitioner also claimed that the expenditures were for
advertising on a local AM radio station, yet insofar as the
records discloses, there was no effort to obtain corroboration
from the station.
Because, for the foregoing reasons, petitioner's testimony
does not persuade us, and there is no other evidence to support
the claimed deductions, we sustain respondent's disallowance of
all deductions claimed on the Schedules C in 1992 and 1993.
Section 6651(a)(1) Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
file a return when due "unless it is shown that such failure is
due to reasonable cause and not due to willful neglect". The
addition equals 5 percent for each month that the return is late,
not to exceed 25 percent in total. The Commissioner has the
burden of production with respect to the liability of an
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