Sandra L. McBrayer - Page 7




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          Petitioner testified that the 1994 receipts represented expenses            
          incurred to replace the two pieces of luggage apparently stolen             
          at Reagan National Airport.                                                 
               Petitioner initially claimed a Schedule C deduction in the             
          amount of $530 for luggage that was destroyed while traveling.              
          At trial, petitioner testified that the luggage had not been                
          destroyed, but had been stolen.                                             
               It is well settled that we are not required to accept                  
          petitioner's self-serving testimony in the absence of                       
          corroborating evidence.  See Niedringhaus v. Commissioner, 99               
          T.C. 202, 212 (1992).                                                       
               Petitioner failed to submit corroborating evidence, such as            
          a police report.  Such evidence would have been helpful in                  
          establishing the items stolen and the date of the theft.                    
          Petitioner also failed to establish that her loss was                       
          uncompensated by insurance and what the fair market value of the            
          luggage or her adjusted basis in the luggage would have been                
          pursuant to section 165(b).                                                 
               Upon the basis of the record, we find that petitioner has              
          failed to establish that her luggage had been stolen, the amount            
          of the loss, and that the loss was not compensated for by                   
          insurance.  We therefore hold that petitioner is not entitled to            
          deduct $530 pursuant to section 165(a).  Respondent is sustained            
          on this issue.                                                              






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