-9- As to the Schedule A deductions in issue, petitioners assert that they had the requisite substantiation to support their claim to those deductions, but their tax records were stolen from their storage facility. Petitioners have failed to submit credible evidence to establish either part of that assertion. In fact, the report of the law enforcement agency investigating the burglary of the location of their storage unit indicates that petitioners’ storage unit was not among those burglarized. Petitioner’s handwritten breakdown of estimated mileage driven in connection with his part-time jobs and his job searching is inadequate to substantiate his mileage deduction. The documents petitioners submitted to substantiate their claim to the personal property taxes deduction are also insufficient in that not one of the documents lists 2000 or 2001 as the years in which personal property tax was paid. Nor does the student loan payment statement substantiate any claim for a student loan interest deduction for 2000 or 2001 as it provides a payment history only for 2002 to 2005. Petitioners presented no evidence at trial, documentary or otherwise, to substantiate expenses related to tuition or books or noncash charitable contributions. We sustain respondent’s determination that petitioners are not entitled to deduct any of the disallowed Schedule A deductions.5 5 While petitioners do not argue application of the rule articulated in Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007