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Ruby contends that the casual labor expenses were for
general property maintenance and upkeep performed by Terry Hosley
(Hosley). Hosley's purported duties included trash removal,
cutting grass, shoveling snow, and raking and bagging leaves.
Ruby contends that she paid Hosley $4,140 and $4,460 in cash for
his services in 1993 and 1994, respectively. Yet, Ruby did not
provide him with a Form 1099 for either year until 1 week before
the trial of this case. Hosley confirmed that he did not receive
a Form 1099 after the close of 1993 or 1994, respectively.
Hosley admitted that he did not file a return for either 1993 or
1994 until sometime in 1998. We did not find Hosley to be a
reliable witness.
Aside from Ruby's self-serving testimony and Hosley's
unreliable testimony, there is no evidence in the record to
support a finding that she paid Hosley $4,140 and $4,460 for his
services in 1993 and 1994, respectively. Ruby failed to provide
details regarding these expenses such as how often Hosley
performed each of his purported duties or how much he was paid
after each time he completed his duties. We have stated on many
occasions that this Court is not bound to accept a petitioner's
self-serving, unverified, and undocumented testimony. Tokarski
v. Commissioner, 87 T.C. 74 (1986); Hradesky v. Commissioner,
supra. With respect to the payments surrounding Hosley's
purported duties, there is no basis upon which an estimate may be
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