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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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Last modified: May 25, 2011