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Petitioners assert that the Code does not detail specifically the
records that must be kept by a sole proprietor like Mr. Harris
and that section 469 was not meant to apply to a small business
like Harris Enterprises.
We agree with respondent that petitioners may not deduct the
disputed amounts. First, we are unpersuaded that petitioners
incurred or paid the amounts claimed for advertising, gravel
parking lot, and water well replacement, or that petitioners had
a depreciable basis in the buildings for which depreciation was
claimed. The regulations mandate that taxpayers "shall keep such
permanent books of account or records * * * as are sufficient to
establish the amount of gross income, deductions, credits, or
other matters required to be shown by such person in any return
of such tax". Sec. 1.6001-1(a), Income Tax Regs. Petitioners
did not comply with this mandate. They did not submit any
credible record to support their claim to any of the disputed
deductions. Nor did they submit canceled checks or bona fide
receipts. Although Mr. Harris testified vaguely as to these
expenditures, we decline to rely on this self-serving and
uncorroborated testimony. Ruark v. Commissioner, 449 F.2d 311,
312 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-48; Clark
v. Commissioner, 266 F.2d 698, 708-709 (9th Cir. 1959), affg. in
part and remanding T.C. Memo. 1957-129; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). We hold that petitioners have failed to
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