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the nature of any of the payments. We also find it
significant that petitioner introduced no testimony or
corroboration from any of his clients concerning the nature
of these payments. We agree with respondent that this
raises an inference that such testimony would not support
petitioner's case. See McKay v. Commissioner, 89 T.C.
1063, 1069 (1987), affd. 886 F.2d 1237 (9th Cir. 1989);
Wichita Terminal Elevator Co. v. Commissioner, 6 T.C.
1158 (1946), affd. 162 F.2d 513 (10th Cir. 1947);
Metals Refining Ltd. v. Commissioner, T.C. Memo. 1993-115.
As mentioned above, petitioner relies entirely on
his own testimony at trial to substantiate the subject
payments. However, petitioner's testimony is extremely
vague. He does not describe the services that he provided
to the subject clients or the nature of the problem with
those services that prompted him to make the payment or
payments with respect to that client. The following
example illustrates petitioner's vague testimony.
Petitioner's testimony regarding two payments made on
behalf of Faith and Joseph Burns is as follows:
The next items is items 22-19, which has to
do with Faith and Joseph Burns. I paid the
Internal Service directly $4,640 and the State
of Massachusetts, which is item 20-22-20--
$1,156. They paid me fees in 1989 of $2,815.
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