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lacks the details of such alleged participation and the details
surrounding the fees allegedly generated from such participation.
Petitioners simply have failed to establish that
petitioner's dominant motivation in guaranteeing the D.B.
Metalworks indebtedness was related to his trade or business as
an attorney, as opposed to that of a mere investor. Petitioners
bear the burden of establishing their entitlement to the
deduction, Rule 142(a), and have not met that burden.
Accordingly, we hold that petitioners are not entitled to their
claimed bad debt deduction in the amount of $28,080.
As to the bad debt deduction claimed by petitioners for the
worthlessness of advances in the amount of $7,020 allegedly made
by petitioner to two or three individuals, petitioners failed to
provide the notes or any other documentary evidence relating to
such advances and sought to substantiate the advances solely
through petitioner's testimony.2 We are not required to accept
petitioner's self-serving and uncorroborated testimony,
particularly where other and better evidence to prove the point
in question should be available. Wood v. Commissioner, 338 F.2d
602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Niedringhaus
v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski v.
2 The record contains only two canceled checks drawn on
petitioner's account that were both written to the same person,
one in the amount of $500 and a second in the amount of $2,500,
and a canceled check drawn on petitioner's account that was
written to Morris State Bank in the amount of $202.50.
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