- 9 - opening brief, petitioners take the position that only the 1989 Southwind motor home was used in connection with Tracstar's business. Based on the record, we find that petitioners have not substantiated with adequate records the extent, if any, that their motor homes were used for business purposes during 1994. We refuse to rely on petitioner's self-serving testimony of the alleged business use of the motor homes because it is not corroborated by any other individual's testimony or any written records of business use. Niedringhaus v. Commissioner, 99 T.C. 202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Other than petitioner's uncorroborated testimony, the only evidence of any business use of the motor homes is several photographs. We find these photographs unreliable because they do not reveal when they were taken and do not identify the motor home pictured. We hold that petitioners are not entitled to interest and depreciation deductions for business use of their motor homes.7 To reflect the foregoing, Decision will be entered under Rule 155. 7 Respondent concedes that petitioners are entitled to an additional qualified residence interest deduction in the amount of $5,579 for interest paid with respect to the motor homes during 1994. See supra note 2.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011