Curtis Muhammad - Page 11

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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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