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figure for any year is substantially greater than the
taxable income reported by the taxpayer for that year,
the Government claims the excess represents unreported
taxable income. [Id. at 125.]
The Commissioner’s determination of tax liability, if
calculated according to an acceptable procedure, such as the net
worth method, is presumptively correct and places the burden of
producing contrary evidence upon the taxpayer. See Helvering v.
Taylor, 293 U.S. 507 (1935); Traficant v. Commissioner, 884 F.2d
258, 263 (6th Cir. 1989), affg. 89 T.C. 501 (1987); Calderone v.
United States, 799 F.2d 254, 258 (6th Cir. 1986). Generally, the
taxpayer will bear the burden of proving by a preponderance of
the evidence that the Commissioner’s determination is “arbitrary
and excessive.” Helvering v. Taylor, supra at 515; Traficant v.
Commissioner, supra at 263; Calderone v. United States, supra at
258.
Petitioner testified on his own behalf. We do not find
petitioner to be a credible witness. Petitioner’s testimony was
self-serving, unbelievable, and uncorroborated. Petitioner’s
testimony at trial also contradicted prior statements he had
made. Petitioner did not call any other witnesses to testify,
nor did he introduce any documents into evidence that would tend
to show that respondent’s determination was “arbitrary and
excessive.”
Petitioner challenges certain items that were included in
the net worth computation. We will address each of these items.
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