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petitioner’s brother-in-law, owns CB Associates.7 Petitioner
claimed a deduction for the rental expense of the printer, but
not the computer, on his return. Although the total lease price
referenced in the invoices is based on a 12-month lease term, the
term referenced on the invoices is for only the 11 months between
January 7 and December 7, 2002.
Petitioner had a checking account in 2002 but purports to
have paid $6,000 using multiple money orders for the lease of the
computer and printer from CB Associates. Petitioner did not
produce any money order receipts or a lease agreement to
substantiate the expense he claimed on his return for the lease
of the printer. Petitioner testified that, after 11 months, he
returned the computer and printer via mail to his brother-in-law
in Houston, Texas.
Bearing in mind the questionable nature of several other
documents that petitioner produced in this case, invoices
purporting to be from a family member at an address that does not
exist are insufficient to substantiate petitioner’s rental
expense deductions. We find that petitioner has failed to meet
his burden of proof and hold that respondent’s determination
6(...continued)
ZIP Code.
7 Petitioner initially testified that Craig Brown was his
father’s son, but he refers to him as his brother-in-law
throughout the rest of his testimony.
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