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in excess of that determined by respondent. Rule 142(a); Burnet
v. Houston, 283 U.S. 223, 227-228 (1931). Petitioner has not
presented any documentation to support his alleged bases in the
automobiles. Indeed, all petitioner offers in support of his
position is his self-serving and totally uncorroborated
testimony, which this Court is not required to accept. Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986).
Petitioner's argument is also inconsistent with a previous
statement made by his representative. In a letter to IRS Special
Agent James P. John dated February 20, 1991, Mr. Asselin provided
petitioner's answers to a series of questions regarding the
automobiles in issue. In response to a question concerning the
acquisition of these automobiles, Mr. Asselin wrote:
Dr. Bennett and Mr. [Abdul] Aziz [Ben-Jabr] were never
in a partnership to acquire antique cars. Mr. Aziz
purchased the cars on his own and had them sent to Dr.
Bennett's home for storage. Dr. Bennett's best
estimate is that Mr. Aziz acquired the cars during the
period of 1974 through 1976. He does not know the cost
of the cars, since they were purchased by Mr. Aziz, or
from whom they were purchased. [Emphasis added]
Suffice it to say, this statement contradicts petitioner's
current argument regarding his bases in several of the
automobiles. Based on the record before us, we also decline to
attempt any estimate of the cost bases for the two automobiles
for which respondent has determined a zero basis, as there is no
reasonable evidentiary basis upon which to do so. See Vanicek v.
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