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introduced no evidence of a security deposit or of a loss of a
security deposit or a loss of any kind.
We have stated on many occasions that this Court is not
bound to accept petitioner's self-serving, unverified, and
undocumented testimony. Tokarski v. Commissioner, 87 T.C. 74, 77
(1986); Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976). Petitioners have failed to
establish that they sustained a $32,500 loss that may be treated
as an ordinary loss under section 1244 for 1993. Thus,
respondent is sustained on this issue.
Finally, we must decide whether petitioners are liable for
an accuracy-related penalty in the amount of $1,729. Section
6662(a) imposes an accuracy-related penalty in the amount of 20
percent of the portion of an underpayment of tax attributable to
negligence or disregard of rules or regulations. Sec. 6662(a)
and (b)(1). Negligence is any failure to make a reasonable
attempt to comply with the provisions of the Internal Revenue
laws. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
Moreover, negligence is the failure to exercise due care or the
failure to do what a reasonable and prudent person would do under
the circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985). Disregard includes any careless, reckless, or
intentional disregard of rules or regulations. Sec. 6662(c);
sec. 1.6662-3(b)(2), Income Tax Regs. No penalty will be imposed
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