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bankruptcy proceeding. However, Mr. Beery did not offer the
transcript as evidence at trial and presented no other factual
testimony or documentation to establish the existence of the
asserted 1975 NOL. Mr. Beery relies solely on his own testimony
to substantiate petitioners’ deductions.
It is well established that this Court is not bound to
accept a taxpayer’s self-serving, unverified, and undocumented
testimony. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
We reject Mr. Beery’s testimony as self-serving and unreliable in
the absence of any credible evidence documenting the existence of
an unused NOL carryforward from 1975 and in view of the Forms
1041 filed by the Kansas bankruptcy trustee, which are in
evidence and show that the 1975 NOL was used fully before the
years at issue.
We hold, therefore, that petitioners are not entitled to
deduct 1975 NOL carryforwards on their 1998 and 1999 tax returns,
and we sustain respondent’s determination on this issue.
II. Charitable Contributions
Petitioners claimed a deduction on their 1998 and 1999 tax
returns for charitable contributions in the amounts of $9,914 and
$12,341, respectively. Respondent disallowed deductions for
charitable contributions of $420 in 1998 and $420 in 1999.
Respondent contends that petitioners have failed to provide the
required documentation to substantiate the deductions.
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