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they appear to be drawn on an account of “Equity Investments”,
for which no expenses are reported on the Schedule E. There are
other checks to Home Depot and Service America, but they also
appear to be drawn on an account of Equity Investments. There is
an IRS Form 1098, showing a mortgage interest payment by
petitioner of $739 to 10 Park Ave. Tenants Corp. Petitioner did
not claim any interest expense on the Schedule E with respect to
the 10 Park Ave. property. Nevertheless, on brief, respondent
appears to concede the deductibility of that payment. We accept
that concession. Other than that, we agree with respondent that
petitioner has failed to substantiate the expenses he reported in
connection with the three rental properties. We are unable to
estimate any such expenses, and, therefore, except with respect
to $739 of interest, we shall allow no deduction for Schedule E
expenses in the computation of the deficiency resulting from this
proceeding.
6. Schedule A Deductions
In computing taxable income, an individual may elect to
itemize certain generally personal deductions or claim a standard
deduction. See sec. 63(a) and (b). The election to itemize is
made on the taxpayer’s return. Sec. 63(e). Similar to his
initial argument with respect to joint return status, respondent
argues that petitioner filed no return for 2000 and, thus, did
not elect to itemize his deductions (and must claim the standard
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