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$83,621 in 1991, and $8,784 in 1992. Petitioner reported
interest income on his tax returns of $771 in 1990 and $80,468 in
1991. Petitioner did not report any interest income in 1992.
Accordingly, we sustain respondent’s determinations that
petitioner failed to report interest income of $3,069 in 1990,
$3,153 in 1991, and $8,784 in 1992.
C. Business Expenses
Section 162(a) allows as a deduction “all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business”. Taxpayers are required to
maintain records that substantiate the amounts of claimed
deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Taxpayers bear the burden of proving that they are entitled to
any claimed deductions. Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992).
Respondent now agrees that petitioner is entitled to deduct
farm expenses of $63,381 in 1990, $54,652 in 1991, and $55,389 in
1992, which are in excess of the amounts petitioner claimed on
his returns. Despite petitioner’s claim that he “had farm
expenses greater than allowed by respondent”, petitioner failed
to offer any documents, records, or other evidence to support his
assertion. We hold that petitioner is entitled to deduct
business expenses in 1990, 1991, and 1992 only as determined by
respondent.
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