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receipts by $7,652.18. Respondent concedes $3,406 of the
adjustment to petitioner's gross receipts. The remaining $3,600
still in issue will be determined by whether the proceeds from the
1989 sale of petitioner's automobile were deposited into the
business account.
In November or December 1989, petitioner sold an automobile
that she had used in her business for $3,600. Petitioner reported
the sale of the automobile on Form 4797 (Sales of Business
Property), which was attached to her 1989 Federal income tax
return. Petitioner claims that the $3,600 was also deposited to
her business bank account and should not be included again as
business gross receipts. Respondent disputes petitioner's claim
that the sales proceeds were deposited into petitioner's business
bank account.
Beyond her own self-serving testimony, petitioner offered no
evidence to establish that the proceeds from the sale of the
automobile were deposited into her business bank account. Although
petitioner points to her filing of the Form 4797 to corroborate her
testimony, the filing of this form does not prove that the proceeds
were deposited into her business bank account. Accordingly, we
hold that petitioner failed to prove respondent's determination
erroneous and sustain respondent's determination of gross receipts
as modified by the parties' respective concessions. See Clark v.
Commissioner, 266 F.2d 698, 708-709 (9th Cir. 1959), remanding T.C.
Memo. 1957-129; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
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