Kai-Chung C. and Meekhing T. Lam - Page 11

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          dated documentation but failed to provide proof of payment.  For            
          expenses attributed to a document that lacks a date or is                   
          otherwise inadequate proof of payment, the only available                   
          evidence that the expense was incurred in the year it was claimed           
          or was actually paid is petitioner’s own self-serving testimony,            
          which we are not required to accept, and which we do not, in                
          fact, find to be credible.  See Niedringhaus v. Commissioner, 99            
          T.C. 202, 219 (1992).                                                       
               Petitioner introduced some documents that indicate date and            
          payment; yet we find the documents or petitioner’s explanations             
          not credible.  For example, petitioner submitted documents he               
          himself wrote because he claimed he used service providers that             
          could not read or write but did not offer testimony from any of             
          these alleged service providers.  We also do not find                       
          petitioner’s explanations for the invoices from his invoice book            
          and those with alterations to be credible.  None of these                   
          invoices was accompanied by third-party testimony.                          
               Second, petitioners contest respondent’s disallowance of               
          supplies expenses.  We note that petitioner submitted many                  
          invoices to support his deductions for supplies.  Petitioner                
          failed, however, to submit corresponding receipts, canceled                 
          checks, or credit card statements that would have shown he paid             
          the amounts indicated on these invoices.  The only available                







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