Bernardus A. P. Dobbe and Klazina W. Dobbe - Page 15




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          Bldg., Inc. v. State, Dept. of Soc. & Health Servs., 702 P.2d               
          459, 461 (Wash. 1985).                                                      
               We are not required to accept the self-serving testimony of            
          a taxpayer or witnesses closely aligned with the taxpayer’s                 
          position in circumstances where the testimony is uncorroborated             
          by other reliable sources and is not credible.  See Tokarski v.             
          Commissioner, 87 T.C. 74, 77 (1986).  The dearth of credible                
          evidence in support of petitioners’ position that an oral lease             
          covered the Dobbe residence during the relevant periods and the             
          failure of petitioners to prove that any rent was paid for the              
          alleged oral lease compel a conclusion that the Dobbe residence             
          was not leased to Holland America.  After evaluating the facts in           
          this record and weighing them against the testimony of Mr. and              
          Mrs. Dobbe and their accountant, we hold that petitioners have              
          failed to prove that Mr. and Mrs. Dobbe orally leased their                 
          residence to Holland America at any time from 1989 through FYE              
          1993.  See Rule 142(a); cf. Ban-Co Inv. Co. v. Loveless, supra at           
          573 (“the existence of the oral agreement was proven by                     
          substantial evidence (including documentary evidence) other than            
          merely the testimony of the parties alleging it”).                          
          II.  Was Holland America Entitled To Deduct Various Expenses as             
          Ordinary and Necessary Business Expenses?                                   
               Section 162(a) permits a taxpayer to deduct expenses paid or           
          incurred during the taxable year in carrying on the taxpayer’s              
          trade or business.  Deductions are strictly a matter of                     





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