Gary Friedmann - Page 40




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             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".                       






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