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self-serving and uncorroborated testimony, particularly where
other and better evidence to prove the point in question is
available. Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir.
1964), affg. 41 T.C. 593 (1964).
The record does not disclose the time and effort expended by
petitioner on her writing activity for taxable years 1989, 1990,
and 1991. However, the bulk of her efforts detailed in the
record were expended before and after the taxable years in issue.
Each of the manuals that petitioner has introduced as her major
income-producing works was written in 1982. Petitioner made
inquiries with publishers and placed her only advertisement for
test marketers during the 1980's. The manuals were self-
published in 1992. Publicity for the manuals and petitioner's
autograph parties occurred no earlier than 1992, and she did not
write to published authors or seek financial assistance until
after 1991. The record raises a strong inference that petitioner
did little or nothing with respect to her writing activity during
the taxable years at issue, 1989-1991.
On their Federal income tax returns for 1987 through 1992
(the only returns submitted into evidence), petitioners never
reported a net profit from petitioner's writing activity. During
that time her writing activity generated losses in excess of
$95,000, which were used to offset petitioners' other taxable
income, including petitioner Dudley J. Callahan's salary for each
year, which far exceeded the amounts involved in petitioner's
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