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there is contrary evidence that petitioner did work for Walter
Capital that was a likely source of income from services
rendered. Cf. Armes v. Commissioner, 448 F.2d 972 (5th Cir
1971), affg. in part, revg. and remanding in part T.C. Memo.
1969-181. Petitioner's self-serving testimony is insufficient to
carry the day for the purpose of disproving respondent's
deficiency determination. Tokarski v. Commissioner, 87 T.C. 74,
77 (1986). Petitioner has failed to meet his burden of proving
that he did not receive the amounts paid to the Joe Bass account
by Walter Capital and that they did not constitute income to him.
We uphold respondent's 1984 deficiency determinations with
respect to the Joe Bass items.
Issue 4: Section 6653(a)(1) and (2)--Negligence
Section 6653(a) provides for an addition to tax if any part
of the underpayment is due to negligence or intentional disregard
of rules and regulations. Section 6653(a)(1) provides for an
addition of 5 percent on the entire deficiency if any part of the
deficiency is due to negligence or intentional disregard of rules
and regulations, and section 6653(a)(2) provides for an addition
equal to 50 percent of the interest due on any part of the
deficiency due to negligence. Sec. 6653(a)(1) and (2). However,
section 6653(b)(3) obviates the addition under this subsection
when there is an addition for fraud under subsection (b) for the
same year. Miller v. Commissioner, 94 T.C. 316, 332 (1990).
Because the fraud addition arising from petitioner's guilty pleas
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