-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
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