Kenneth D. Shepherd and Martha A. Gregory - Page 6

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          activity; (2) the expertise of the taxpayer or his advisers; (3)            
          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that the assets used in the                   
          activity may appreciate in value; (5) the success of the taxpayer           
          in carrying on other similar or dissimilar activities; (6) the              
          taxpayer's history of income or losses with respect to the                  
          activity; (7) the amount of occasional profits, if any, which are           
          earned; (8) the financial status of the taxpayer; and (9) whether           
          elements of personal pleasure or recreation are involved.                   
               Petitioners failed to produce books or records supporting              
          the existence of a profit-seeking business, aside from two                  
          personal planning diaries that contained vague notations.  In               
          addition, their income from this activity was sporadic and                  
          unsubstantiated.  At trial, petitioner husband was able to recall           
          only three clients during 1991 and 1992 aside from petitioner               
          wife's brother.  Petitioner husband testified that they received            
          $700 from their research activity from these clients, although it           
          was possible that $100 of that amount may have been received                
          during 1990.  In addition, one of the alleged clients did not pay           
          petitioners for services rendered.  No records were offered to              
          substantiate the billing of these clients or the receipt of                 
          payments.  We are not required to accept the self-serving                   
          testimony of taxpayers without further corroborating evidence.              
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                            






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