- 40 - testimony regarding the payments fails to provide sufficient information regarding the "supplies" purchased or the "consulting and legal work" actually performed. As stated earlier, we are not required to accept a tax- payer's self-serving testimony. See, e.g., Neidringhaus v. Commissioner, 99 T.C. at 219-220; Tokarski v. Commissioner, 87 T.C. at 77; Hradesky v. Commissioner, 65 T.C. at 90. For the above reasons, we hold that petitioner has failed to establish that he is entitled to a deduction for these payments, and we sustain respondent on this issue. C. Reimbursed Payments Allegedly Made on Behalf of One Client Included among the subject returns and allowances for 1990 are payments totaling $21,679.75, that petitioner allegedly made on behalf of a client, Dr. Strom, for licensing fees and tax liabilities. Petitioner asserts that Dr. Strom reimbursed petitioner for these payments, as discussed below, and that they should be treated as offsets to gross income or as ordinary and necessary business expenses under section 162. In passing, we note that petitioner allegedly made two other payments on behalf of or to Dr. Strom in 1990, $59.02, and $930, that petitioner also treated as "direct payments".Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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