Stan Pyron and Ruth S. Pyron - Page 9

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          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;            




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