Dudley Joseph and Myrna Dupuy Callahan - Page 10

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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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