-7- respectively. On the basis of third party information returns, respondent also concedes that under section 163 petitioner is entitled to Schedule A deductions for mortgage interest expenses in the amounts of $22,000, $18,933, $17,909, and $16,661 for taxable years 2000, 2001, 2002, and 2003, respectively. We accept these concessions. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). As to the remaining expenses, petitioner offered no evidence that he actually incurred them or that he is entitled to a deduction for them, and therefore he has not met his burden of proving that he is entitled to claim deductions for any expenses to the extent that they exceed respondent’s concessions. Petitioner’s Audit Request Petitioner asks that we allow him to audit the Organization, which is not a party to this case, and that he be able to pay his taxes out of the proceeds of that audit. There is no provision in the Code that gives us the authority to allow one taxpayer to audit another taxpayer in order to reduce his tax deficiency. Therefore, we deny petitioner’s request. Additions to Tax Section 6651(f) and (a) Respondent asserts that petitioner is liable for an addition to tax under section 6651(f) for each year in issue. Section 6651(f) imposes a penalty of up to 75 percent of the amount ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008