Edward Nathan Levine - Page 15

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               It is well established that we are not required to accept              
          self-serving testimony in the absence of corroborating evidence.            
          Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski             
          v. Commissioner, supra at 77. Moreover, our analysis of                     
          petitioner's testimony reveals inconsistencies that cast doubt              
          upon his credibility.  Thus, there is no credible evidence that             
          the money actually belonged to Cos and Bro.  Upon the basis of              
          the entire record, we simply do not believe that the money came             
          from the source petitioner claims.  We find, therefore, that                
          petitioner has not met his burden of proving a nontaxable source            
          of the unreported income.                                                   
          Issue 2.  Additions to Tax for Fraud                                        
               Respondent asserts as his primary position that petitioner             
          is liable for additions to tax for fraud pursuant to section                
          6653(b)(1)(A) and (B) for 1987, and section 6653(b)(1) for 1988.            
          Petitioner asserts that respondent has failed to prove that the             
          funds deposited in the various safe deposit boxes were his                  
          income, and that without such proof inferences of fraud cannot be           
          drawn from his use of fictitious names and his concealment of the           
          cash.                                                                       
               The existence of fraud is a question of fact to be resolved            
          upon consideration of the entire record.  Gajewski v.                       
          Commissioner, 67 T.C. 181, 199 (1976), affd. without published              
          opinion 578 F.2d 1383 (8th Cir. 1978).  Fraud is not to be                  
          imputed or presumed.  Beaver v. Commissioner, 55 T.C. 85, 92                
          (1970); Otsuki v. Commissioner, 53 T.C. 96 (1969).  Respondent              



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