- 4 - not allowed as a deduction unless the income such items represent has been included in the return of income for the year for which the deduction as a bad debt is claimed or for a prior taxable year. See Gertz v. Commissioner, 64 T.C. 598 (1975); Garrison v. Commissioner, T.C. Memo. 1994-200, affd. without published opinion 67 F.3d 299 (6th Cir. 1995); sec. 1.166-1(e), Income Tax Regs. At trial, petitioners submitted various stopped checks and work orders and claimed that these items substantiate their claimed bad debt deductions. Contrary to petitioners' assertions, these documents do not demonstrate that the income which gave rise to these items was in fact included in their gross income. Although petitioner was a well-spoken witness, he has not furnished any documentation that would corroborate his position. In the present case, we cannot rely upon petitioner's self-serving, uncorroborated testimony. See Niedringhaus v. Commissioner, 99 T.C. 202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). The tax law requires taxpayers to substantiate amounts claimed as deductions by maintaining the records necessary to establish such entitlement. See Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax Regs. During the trial, petitioner admitted that he destroyed the worksheets that he claims might have substantiated his position. Moreover, petitioners have not submitted evidence thatPage: Previous 1 2 3 4 5 6 Next
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