- 3 - 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.Page: Previous 1 2 3
Last modified: May 25, 2011