AJF Transportation Consultants, Inc. - Page 17




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             where the taxpayer also showed that he had offsetting deductions                                     
             relating to such receipts that he failed to claim on his return.                                     
             Zack v. Commissioner, T.C. Memo. 1981-700, affd. 692 F.2d 28 (6th                                    
             Cir. 1982).                                                                                          
                    The taxpayers in Perez, Richardson, and H.J. Feinberg & Co.,                                  
             Inc. submitted positive proof that unreported deductible payments                                    
             were in fact made and were related to their respective unreported                                    
             receipts.  Zack v. Commissioner, supra.  Based on such proof, the                                    
             courts shifted the burden of going forward to the Commissioner to                                    
             prove that at least some unreported net income resulted from the                                     
             unreported transactions.  Id.  Therefore, to shift such burden to                                    
             respondent, Ferrentino must submit credible evidence of whether                                      
             and to what extent he made such payments.                                                            
                    The underlying support for Ferrentino's claimed "casual                                       
             labor" cash payments rests on Ferrentino's credibility, on the                                       
             testimonial credibility of AJF's employees, and on a report                                          
             authored by Elaine Brittain (Brittain), AJF's office manager.                                        
                    It is well established that we are not required to accept                                     
             self-serving testimony in the absence of corroborating evidence.                                     
             Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski                                      
             v. Commissioner, 87 T.C. 74, 77 (1986).  Ferrentino testified                                        
             that he cashed the checks when he needed funds to pay for casual                                     
             labor.  Brittain testified that she obtained cash from Ferrentino                                    
             to cover shortages of COD funds received by the drivers.  But                                        
             Brittain's testimony indicates that she did not have personal                                        
             knowledge of a casual laborer ever working at AJF.  Donald                                           

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