-422-
The above * * * claimed investment interest expense
[from GLS Associates] is disallowed because you have
not substantiated that the entity was engaged in an
activity entered into for profit or that the investment
interest expense was paid or incurred by the entity
during the taxable year, or if paid or incurred, was
deductible.
OPINION
A. The Parties’ Arguments
Petitioners essentially advance the same arguments they
raised above relating to (1) the partnership loss they claimed
with respect to GLS Associates for 1981; and (2) the loss they
claimed from Equitable Leasing for 1984, which the Court has
rejected. Petitioners contend the GLS Associates leasing
transaction in issue is substantially the same as the SLG
Partners’ leasing transactions and the Court should consider
Kanter’s experience with other entities in the equipment leasing
field.
Respondent contends petitioners failed to carry their burden
of proof on this issue under Rule 142(a).
B. Analysis
Petitioners failed to offer sufficient substantive evidence
concerning GLS Associates’ purported leasing transaction and GLS
Associates’ claimed investment interest expense for 1981 to
sustain their burden of proof. Self-serving legal arguments on
brief are not evidence and do not suffice to sustain the burden
of proof. For instance, even assuming for the sake of argument
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