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amount paid for legal expenses on behalf of Group M, but stated
that the amount was substantially more than $25,000. There are
no documents in evidence that substantiate petitioners' claim
that petitioner incurred legal expenses on behalf of Group M.
Petitioners contend that the testimony of petitioner and his
brother “was straight forward and credible.” We disagree. The
self-serving testimony of petitioner, vaguely corroborated only
by the testimony of his brother, does not persuade us that the
payment represents reimbursement of legal fees paid by petitioner
on behalf of Group M. Cf. Day v. Commissioner, 975 F.2d 534, 538
(8th Cir. 1992) (“The Tax Court is not required to give credence
to the self-serving testimony of interested parties.”), affg. in
part and revg. in part T.C. Memo. 1991-140; Geiger v.
Commissioner, 440 F.2d 688 (9th Cir. 1971) (this Court did not
err when it found that taxpayer's uncontradicted testimony plus
the testimony of her accountant, both unsubstantiated by any
documentary evidence, did not carry the burden of proof), affg.
T.C. Memo. 1969-159. Petitioners have failed to carry their
burden of proof. Therefore, we conclude that the $25,000 deposit
is taxable to petitioners.
IV. Penalty
Section 6662(a) provides for an accuracy-related penalty in
the amount equal to 20 percent of the portion of an underpayment
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