Conrad Fitzgerald Lewis - Page 25

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          the employment.  See Evans v. Commissioner, T.C. Memo. 1974-267,            
          affd. 557 F.2d 1095 (5th Cir. 1977).  The taxpayer bears the                
          burden of substantiation.  Hradesky v. Commissioner, 65 T.C. 87,            
          90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).                   
               Petitioner testified that the unreimbursed employee expenses           
          were paid in furtherance of his occupation as a truck driver.               
          Once again, petitioner provided no documentation that would                 
          substantiate that he paid the claimed expenses or that the                  
          alleged expenses were related to his employment as a truck                  
               On the basis of the record in this case, we conclude that              
          petitioner has not substantiated any unreimbursed employee                  
          expenses for taxable year 2000 in excess of the amount allowed by           
          respondent.  Accordingly, respondent’s determination on this                
          issue is sustained.                                                         
          5.   Interest Income                                                        
               Petitioner timely filed his Federal income tax returns for             
          taxable years 2000 and 2001 without reporting any interest                  
          income.  Respondent, in the notice of deficiency, determined that           
          petitioner received interest income of $113 and $41 for taxable             
          years 2000 and 2001, respectively.                                          
               The law is clear.  Gross income includes all income from               
          whatever source derived.  Sec. 61(a).  Section 61(a)(4)                     
          specifically includes income derived from interest.                         

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