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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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