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with those consulting services, and that the Internal Revenue
Service audited petitioners and ultimately issued a “no change”
on their tax return. The record is devoid of any evidence
regarding the 1991 audit except for petitioner’s brief self-
serving testimony on the topic.8 We are not obligated to accept
the self-serving and uncorroborated testimony of petitioner under
these circumstances. See Tokarski v. Commissioner, 87 T.C. 74
(1986). Other than petitioner’s testimony regarding the prior
audit, petitioner has offered no evidence to prove that
petitioners are entitled to relief from the accuracy-related
penalty. We conclude, therefore, that petitioners have failed to
carry their burden of proof and are liable for the accuracy-
related penalty under section 6662.
We have carefully considered all remaining arguments for
contrary holdings and, to the extent not discussed, find them to
be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
8The additional factual assertions in petitioners’ reply
brief are not part of the evidentiary record. See Rule 143(b).
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