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Petitioner did not introduce testimony or other evidence
from either Peat Marwick or the Macks. In fact, petitioner
failed to present any evidence, other than his own testimony, to
corroborate his argument that Peat Marwick improperly omitted the
$4 million from the Schedule K-1 for the Bilzerian & Mack
partnership return for 1986 and that petitioner was not aware of
the characterizations made by Peat Marwick. In addition,
petitioner’s amended 1986 return reports the previously omitted
$4 million as “Adjustments to Schedule C - Income From Sales”.
This is consistent with Peat Marwick’s original characterization
of this amount as “Personal Gain” and inconsistent with
petitioner’s argument that it was income from the partnership.
In this situation, we are not required to, and we do not, rely on
petitioner’s self-serving testimony. Tokarski v. Commissioner,
87 T.C. 74, 77 (1986).
Petitioner argues that Mr. Norris’s testimony supports his
claim that the $4 million omission was a result of Mr. Norris’s
mistake. Mr. Norris testified that he learned in 1988 that he
had made a mistake in preparing petitioner’s 1986 return because
he “missed about $4 million in income”. However, Mr. Norris’s
testimony was vague, evasive, and contradictory.10 The following
10We note that Mr. Norris was previously a partner of
petitioner’s, and Mr. Norris, a resident of California, testified
that at the time of trial he stayed at petitioner’s personal
residence in Tampa, Florida.
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