-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 of
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