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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.
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