- 15 - 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 ofPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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