James W. Harris and Dorthy R. Harris - Page 10

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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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