- 33 - 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 substantiatePage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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