Gary Friedmann - Page 33




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             or statements issued by the taxing authority.  The                       
             documentary evidence petitioner introduced supports a                    
             finding that petitioner made payments to his clients, to                 
             the Internal Revenue Service, and to various State tax                   
             administrators.  However, the documentary evidence does not              
             explain why the payments were made, what connection any of               
             the payments had to petitioner's Schedule C business, or                 
             why these payments are ordinary and necessary business                   
             expenses.  For this, petitioner relies upon his own                      
             uncorroborated testimony at trial.  As we have often                     
             stated, we are not required to accept a taxpayer's                       
             self-serving testimony.  See, e.g., Neidringhaus v.                      
             Commissioner, 99 T.C. 202, 219-220 (1992); Tokarski                      
             v. Commissioner, 87 T.C. 74, 77 (1986); Hradesky v.                      
             Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam                    
             540 F.2d 821 (5th Cir. 1976).                                            
                  We have difficulty accepting petitioner's testimony                 
             that he made 27 payments totaling $59,674.83 (i.e., total                
             direct payments of $113,317.83 less the amount allowed by                
             respondent, $53,643) in 1989 and 18 payments totaling                    
             $81,669.93 in 1990 to settle malpractice claims with 17                  
             clients.  Petitioner claims to have made these payments,                 
             but he failed to produce documents of any kind, such as                  
             agreements, correspondence, or memoranda, to substantiate                






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