Roger L. and Geraldine Williams - Page 11

                                        -11-                                          
               In view of the foregoing, respondent's determinations                  
          regarding the deductions claimed for "Car & Truck" and "Rent,               
          vehicles" are sustained.                                                    
          2.  Insurance                                                               
               Petitioners claimed a deduction for "Insurance" in the                 
          amount of $270.  Petitioners contend that this deduction                    
          represents two premiums paid to State Farm for policies required            
          by the Port lease.  In this regard, petitioners claim that a                
          premium of $150 was paid for a $1 million liability policy and              
          another premium of $120 was paid for a $1 million bond.                     
          Respondent allowed a deduction for the $150 premium paid for the            
          liability policy but disallowed the balance of the deduction for            
          lack of substantiation.                                                     
               In deciding whether a taxpayer has satisfied his or her                
          burden of substantiating a deduction, we are not required to                
          accept the taxpayer's self-serving, undocumented testimony.                 
          Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41           
          T.C. 593 (1964); Niedringhaus v. Commissioner, 99 T.C. 202, 219-            
          220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986);                
          Hradesky v. Commissioner, 65 T.C. at 90.                                    
               Petitioners presented no evidence at trial that the Port               
          lease required a $1 million bond in addition to liability                   
          coverage in the amount of $1 million.  The copy of the lease                
          introduced into evidence contains no requirement for such a bond.           
          Moreover, the lease recites that it is a complete contract of               




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011