- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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