- 17 -17
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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