Daniel V. Presnick - Page 5

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               Petitioner did not call any witnesses, and relies solely               
          upon his own testimony in support of his position.  It is well              
          established that, in the absence of corroborating evidence, we              
          are not required to accept the self-serving and unverified                  
          testimony of taxpayers.  Niedringhaus v. Commissioner, 99 T.C.              
          202, 212 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).           
               Based on the limited record in this case, we find that                 
          petitioner has not proved that he did not receive nonemployee               
          compensation in the amounts determined by respondent, apart from            
          the amount conceded by respondent for 1990.  Further, he has not            
          proved that he is entitled to any deductions for advances on                
          behalf of Florida Realty or windup expenses for his law practice,           
          or the amounts thereof.  Respondent's determinations on this                
          issue are therefore sustained.                                              
               The second issue for decision is whether petitioner is                 
          liable for the section 6651(a)(1) additions to tax for 1990,                
          1991, 1992, and 1993.                                                       
               Section 6651(a)(1) imposes an addition to tax for failure to           
          timely file a return, unless the taxpayer establishes:  (1) The             
          failure did not result from "willful neglect," and (2) the                  
          failure was "due to a reasonable cause".  "Willful neglect" has             
          been interpreted to mean a conscious, intentional failure or                
          reckless indifference.  United States v. Boyle, 469 U.S. 241,               
          245-246 (1985).  "Reasonable cause" requires the taxpayer to                
          demonstrate that he exercised ordinary business care and prudence           

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