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therefore imposed the accuracy-related penalty under section
6662(a) on each such underpayment.5
OPINION
Petitioner bears the burden of proving that the determina-
tions in the notice are erroneous. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Petitioner attempted to
satisfy that burden through his own testimony and certain docu-
mentary evidence. We found petitioner’s testimony to be ques-
tionable, vague, conclusory, evasive, and/or uncorroborated in
certain material respects. Under these circumstances, we are not
required to, and we shall not, rely on petitioner’s testimony to
sustain his burden of establishing error in the determinations of
respondent that remain at issue. See Lerch v. Commissioner, 877
F.2d 624, 631-632 (7th Cir. 1989), affg. T.C. Memo. 1987-295;
Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971),
affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). As for the documentary evidence on which
petitioner relies, except as discussed below, we are not per-
suaded by that evidence that the determinations which respondent
does not concede are wrong.6
5Because of the determinations in the notice that increased
self-employment income, respondent also determined in the notice
to make correlative adjustments to self-employment tax for 1994
and 1995.
6We note that petitioner attempted to attach to his opening
(continued...)
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