Donald Francis Cook - Page 3

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          reported in Schedule C for each of the years 1994 and 1995 and              
          corresponding adjustments to petitioner's self-employment tax for           
          each of those years.  Respondent also determined in the notice              
          that petitioner is liable for the accuracy-related penalty under            
          section 6662(a) for each year at issue.                                     
               Petitioner bears the burden of proving that the determina-             
          tions in the notice are erroneous.  See Rule 142(a); Welch v.               
          Helvering, 290 U.S. 111, 115 (1933).  Petitioner attempted to               
          satisfy that burden through his self-serving testimony, which was           
          largely general, vague, irrelevant, and/or conclusory.  We are              
          not required to, and we shall not, rely on that testimony.  See             
          Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),               
          affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,            
          689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;              
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                            
               We have considered all of the arguments and contentions of             
          petitioner, and we find them to be without merit and/or irrele-             
          vant.  Based on our examination of the entire record in this                
          case, we find that petitioner has failed to satisfy his burden of           
          showing error in any of the determinations in the notice that               
          have not been conceded by respondent.                                       
               To reflect the foregoing and the concessions of respondent,            

                                             Decision will be entered under           
                                        Rule 155.                                     

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