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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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