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Even if petitioner was entitled to reimbursement for
expenses but was, in fact, not reimbursed, he is not allowed a
deduction for such expenses. A taxpayer is not entitled to a
deduction for expenses to the extent that the taxpayer is
entitled to reimbursement where the taxpayer does not claim
reimbursement. Levy v. Commissioner, 212 F.2d 552, 554 (5th Cir.
1954), affg. a Memorandum Opinion of this Court; Universal Oil
Prods. Co. v. Campbell, 181 F.2d 451, 475 (7th Cir. 1950); see
also Lucas v. Commissioner, 79 T.C. 1, 7 (1982); Kennelly v.
Commissioner, 56 T.C. 936, 943 (1971), affd. without published
opinion 456 F.2d 1335 (2d Cir. 1972); Stolk v. Commissioner, 40
T.C. 345, 356 (1963), affd. per curiam 326 F.2d 760 (2d Cir.
1964); Podems v. Commissioner, 24 T.C. 21, 22-23 (1955); Roach v.
Commissioner, 20 B.T.A. 919, 925-926 (1930).
Moreover, if there was a bona fide debt owing to petitioner,
he provided no evidence that the debt became worthless during the
year at issue. Sec. 1.166-2, Income Tax Regs. Petitioner
offered only his unsupported opinion as to when the debt became
worthless. A taxpayer’s unsupported opinion that a debt became
worthless in a particular year by itself will not normally be
accepted as proof of worthlessness. Dustin v. Commissioner, 53
T.C. 491, 501-502 (1969), affd. 467 F.2d 47 (9th Cir. 1972).
Respondent is sustained on this issue.
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