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