Robert B. Keenan - Page 12

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          to store his personal aircraft.  Moreover, petitioner neither               
          developed the two 1-acre lots nor made any attempts to lease or             
          rent them.  Petitioner was not a real estate developer and had no           
          history of buying and selling real properties.  Rather, he spent            
          the majority of his working life as a pilot for United Airlines.            
          We need not, and do not, accept petitioner's self-serving testimony         
          in the absence of corroborating evidence. See Niedringhaus v.               
          Commissioner, 99 T.C. 202, 212 (1992). Thus, we hold that                   
          petitioner did not use the two 1-acre lots and the airplane hangar          
          in a trade or business.  Accordingly, we sustain respondent on this         
          issue.                                                                      
          Issue 6.  Other Deductible Losses                                           
               The sixth issue is whether petitioner is entitled to any               
          other deductible losses (namely, with respect to funds he invested          
          in foreign trusts) for 1992.  Petitioner believes he is so                  
          entitled.  Respondent disagrees.                                            
               At trial, petitioner claimed that he incurred a $521,000 loss          
          in 1992 from his foreign trusts.  The only evidence petitioner              
          presented in this regard was an October 26, 1992, letter to him             
          from Bernard Putz (who is not described in the record), stating             
          that the account had "sustained a loss of US$521,000 and was                
          automatically liquidated".                                                  
               As stated earlier, deductions are a matter of legislative              
          grace.  New Colonial Ice Co. v. Helvering, supra.  We hold that             





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