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startup expenses on petitioners' respective 1988 returns by
introducing a completed Form 4562, Depreciation and Amortization,
as well as accompanying work papers purportedly drafted while
preparing petitioners' 1988 returns. Petitioner did not provide
respondent with these documents prior to trial.
We are troubled by petitioners' failure to provide
respondent with the documentation concerning their election to
amortize startup expenses until the date of trial. Nevertheless,
we have reviewed these documents and find them insufficient for
the purposes of satisfying petitioners' burden, particularly when
the record does not contain petitioners' 1988 returns. We are
not required to accept petitioner's self-serving testimony.
Masters v. Commissioner, 243 F.2d 335, 338 (3d Cir. 1957), affg.
25 T.C. 1093 (1956); Tokarski v. Commissioner, 87 T.C. 74, 77
(1986). We find that petitioners have failed to meet their
burden of proving that they executed a timely election to
amortize startup expenditures. Therefore, petitioners are not
entitled to amortize the startup expenditures claimed during the
years in issue. Krebs v. Commissioner, T.C. Memo. 1992-154.
In addition to finding that petitioners failed to execute a
timely election, we also agree with respondent's second argument.
In an attempt to substantiate their purported startup
expenditures, petitioners have offered a list of the various
expenditures incurred between 1982 and January 1, 1988, the date
on which they officially commenced operation of Arabian Hill.
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