Brett W. Barnes - Page 3

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          deductions and allowed him a standard deduction in the amount of            
          $3,600 for an individual filing as an unmarried individual.                 
               Petitioner's case was first called for trial on October 8,             
          1996.  Since the parties had not executed stipulations of fact,             
          the Court ordered that the case be continued to allow petitioner            
          the opportunity to stipulate all documentary and written evidence           
          in support of his claimed itemized deductions in accordance with            
          the Court's standing pretrial order and Rule 91(a).                         
               On June 10, 1997, this case was again called for trial.  In            
          the interim, respondent had advised petitioner to get copies of             
          doctor and hospital bills, canceled checks, and credit card                 
          statements.  At trial, petitioner acknowledged that he received             
          respondent's letter but admitted that he took no action to obtain           
          such records.                                                               
               Respondent's determinations in the statutory notice of                 
          deficiency are presumed to be correct, and petitioner bears the             
          burden of proving otherwise.  Rule 142(a); Welch v. Helvering,              
          290 U.S. 111, 115 (1933).  In deciding whether this burden is               
          satisfied, the Court is not bound to accept petitioner's self-              
          serving, unverified, and undocumented testimony.  Wood v.                   
          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964); Niedringhaus v. Commissioner, 99 T.C. 202, 219-220              
          (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Hradesky           
          v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d           
          821 (5th Cir. 1976).  Taxpayers are required to substantiate                

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