- 9 - did not establish that the advances to CME/CMA in the amount of $633,897 were bona fide debt. As to the second bad debt deduction for the worthlessness of loans made by petitioners to CME/CMA in the amount of $4,010, petitioners provided no business records, checks, or receipts to corroborate petitioner's testimony that the amount was actually advanced. It is well established that, in the absence of corroborating evidence, we are not required to accept self- serving testimony. Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); see Jackson v. Commissioner, 19 T.C. 133, 145 (1952), affd. 207 F.2d 857 (10th Cir. 1953). Consequently, we conclude that petitioners did not establish that the advances to CME/CMA in the amount of $4,010 were bona fide debt. As to petitioners' remaining arguments, we conclude that petitioners have not carried their burden of proving that they are entitled to the alleged losses. As we stated above, petitioners provided no books, records, or tax returns with respect to their interests in CME or CMA. Additionally, petitioners did not provide promissory notes evidencing the alleged loans to CME/CMA or books and records reflecting petitioners' lending activities. Taxpayers are required to maintain records that are sufficient to enable the Commissioner to determine their correct tax liability. See sec. 6001; Meneguzzo v. Commissioner, supra;Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011