Bruce L. Helmich - Page 9




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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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