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back taxes, but balances remain that are consistent with the
amounts that respondent is now attempting to collect.
Petitioner alleges that he previously entered into an
agreement with the IRS, pursuant to which certain amounts were
withheld from his paychecks and remitted to the IRS to cover his
back taxes. Petitioner also contends that he sent money orders
to the IRS’s Chicago office to pay some of his back taxes.
Petitioner failed to present credible evidence of his
alleged payment agreement with the IRS or of the amounts he
alleges were withheld from his paychecks or otherwise paid to
respondent. Petitioner’s self-serving, uncorroborated testimony
inadequately substantiates the alleged payments. See Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986).
Petitioner did introduce into evidence two 1998 paycheck
stubs that indicate two separate withholdings of $157.43, listed
on each paycheck stub as “MISC. DEDUCTIONS”. Petitioner
handwrote “IRS Levy Proceeds” on one of the paycheck stubs.
Respondent’s transcripts for taxable year 1989 show one $157.43
payment credited to petitioner’s account. There is no evidence
to establish that the other alleged payment, if it was in fact
made, should have been credited to petitioner’s tax liabilities
for taxable years 1991, 1992, 1993, 1996, or 1997, which are the
only years for which petitioner has argued that respondent failed
to give him proper credit for payments made.
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Last modified: May 25, 2011