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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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