- 21 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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