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this Court. If, on the other hand, petitioner did receive the
money, then he failed to properly amend his 1996 tax return, he
lied to the Internal Revenue Service, he accused an innocent man
of committing a crime, and he committed perjury when he testified
before the Court. Fortunately, it is not necessary to decide
which of these scenarios actually occurred.
Respondent introduced into evidence three letters from
petitioner stating that petitioner received $10,638 as a bonus
during his employment with Mr. Vaughan. Petitioner admitted
writing these letters. In contradiction to these letters, we are
faced with petitioner’s testimony. We are not required to accept
a taxpayer’s self-serving and uncorroborated testimony. Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 TC 593
(1964); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). In this
case, we find that petitioner's testimony carries no weight due
to his lack of credibility. Petitioner did not meet his burden
of proof. The letters, which are admissions against interest,
are convincing.
Under section 61(a)(1), gross income includes all income
from whatever source derived, including compensation for
services. We note that this includes employee compensation as
well as nonemployee compensation. We find that petitioner
received $10,638 as employee compensation for his services in
1996. Accordingly, we sustain respondent's determination.
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