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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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