William Lenihan - Page 24

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          Schedule E expenses.  Respondent does not stipulate that the                
          documents making up the exhibit substantiate the claimed                    
          expenses.  The documents suffer from defects similar to those               
          affecting the documents petitioner produced to substantiate his             
          Schedule C deductions.  Some of the documents seem to have no               
          connection with the claimed expenses at all; others are ambiguous           
          or confusing.  There are, for example, nine pages of copies of              
          checks payable to the order of “200 East 36th St., Owners [or               
          ‘Tenants’ or something similar]”, some of which refer to                    
          apartments “8-B” and “4-H”, and some of which refer to monthly              
          maintenance.  There is also an IRS Form 1098, Mortgage Interest             
          Statement, for 2000, showing a mortgage interest payment by                 
          petitioner of $2,313 to 200 East 36th Owners Corp.  We fail to              
          see the relationship of those checks and that interest payment to           
          the expenses claimed for the three rental properties, none of               
          which seem to involve the address 200 East 36th Street.  There is           
          a receipt for $128 paid for a magazine described as “Financial              
          Planning[,] Elderly Finances”, but containing no indication of              
          who made the payment.  There is a receipt from the bookseller               
          Barnes & Noble for something called “Say It In Spanish”, which is           
          annotated “Pace U”.  There is another partially illegible receipt           
          which is annotated “YMCA”.  We fail to see the relevance of those           
          receipts to the claimed expenses.  There are three checks drawn             
          to the order of “Delray Racquet Club” and annotated “4303”, but             






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