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what records were allegedly lost. Rather, petitioner syllogizes
as follows: He faithfully maintained complete and accurate
records that substantiated every dollar of deduction claimed on
his income tax returns; when he attended the Problem Solving Day
in April 1998, his records substantiated only 85 percent of the
total deductions claimed on his Schedule C for 1986; therefore,
respondent must have lost the records that would have
substantiated the remaining 15 percent of those deductions.
Petitioner’s syllogism is, of course, self-serving. See
Tokarski v. Commissioner, supra; cf. Seaboard Commercial Corp. v.
Commissioner, 28 T.C. 1034, 1051 (1957) (a taxpayer's income tax
return is a self-serving declaration that may not be accepted as
proof for the deduction or exclusion claimed by the taxpayer);
Halle v. Commissioner, 7 T.C. 245 (1946) (same), affd. 175 F.2d
500 (2d Cir. 1949). Moreover, the primary premise of the
syllogism; i.e., that petitioner maintained impeccable records,
is suspect, as demonstrated by the following:
In January 1988, during the course of the examination of
petitioner’s 1985 income tax return, Mr. Davis, petitioner’s
certified public accountant and representative, described a
telephone conversation with respondent’s revenue agent in which
the agent was said to state that he was “going to disallow all
deductions due to the fact that the amounts originally claimed
could not be reconciled to the amounts which were documented upon
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