- 15 - Although we conclude that the photocopy of the lease agreement is admissible, we remain unconvinced that petitioners have satisfactorily proven their entitlement to a deduction of $7,200 for lease of the sewing machines. We are not convinced that the lease agreement establishes conclusively that petitioners disbursed the monthly payments called for therein. Petitioner Bui produced the only testimony with regard to this issue, and we are not required to accept her self-serving testimony. Niedringhaus v. Commissioner, 99 T.C. 202 (1992). Additionally, petitioner Bui's testimony is less than credible with regard to this matter. Petitioner Bui first testified that she paid 3 months' rent in advance when she picked up the sewing machines in January 1988. Petitioner Bui subsequently testified that she paid the first 3 months' rent in late February 1988. It is the occurrence of inconsistencies such as this that cast doubt on the credibility of petitioners' argument. Petitioners have failed to establish their entitlement to a business expense deduction with respect to the $7,200. Accordingly, respondent's determination is sustained as to this issue. Issue 3. Unreported Income In the notice of deficiency issued to petitioners for taxable year 1988, respondent adjusted petitioners' gross receipts by $63,847. After concessions by the parties, the amount in dispute has been reduced to $14,000. PetitionersPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011