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nothing in the record showing that petitioner held any of those
assets for more than 1 year. As with petitioner’s bases in his
interests in Oxford and Kemper, we think it appropriate that
petitioner bear the burden of producing evidence showing a
holding period greater than 1 year. Petitioner has failed to
carry that burden, and we conclude that he had no holding period
greater than 1 year in his interests in Oxford, Kemper, Ford, or
Citicorp.
d. Loss Carryover
Petitioner reported on the Schedule D a long-term capital
loss carryover (from 1999) of $18,742. Respondent argues that
petitioner is entitled to no capital loss carryover since he has
failed to prove that he actually suffered any loss entitling him
to a capital loss carryover to 2000. Respondent is again correct
that there is nothing in the record other than the Nov. 10 return
and petitioner’s otherwise unsubstantiated testimony showing that
he suffered a capital loss that could be carried to 2000. We
need not accept a taxpayer’s unsubstantiated testimony. See
Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41
T.C. 593 (1964). Indeed, respondent’s records show that,
contrary to petitioner’s claim that he filed a return for 1999 on
which the claimed loss can be found, he filed no return for 1999.
Because of the lack of evidence corroborating his testimony, and
the evidence that petitioner filed no return for 1999, we
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