- 12 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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