John R. Hernandez - Page 8




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          to his testimony.  We are not required to rely upon self-serving            
          testimony.  Niedringhaus v. Commissioner, 99 T.C. 202, 219-220              
          (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).  We do             
          not find Vincent’s testimony to be credible.                                
               There are no agreements or other written documentation that            
          petitioner received the income in question as a nominee, agent,             
          or conduit for others.  Petitioner also failed to provide any               
          credible evidence that any of the interest income was transferred           
          to other individuals, and that the individuals reported the                 
          income on their Federal income tax returns.                                 
               Yet again, petitioner failed to corroborate his story.  For            
          the same reasons as in Hernandez I and II, we sustain                       
          respondent’s determination for 1993, 1995, 1996, and 1997 that              
          the interest income from the tax certificates is includable in              
          petitioner’s income under section 61(a)(4).                                 
               2. Rental Property Expenses                                            
               Petitioner deducted $10,202, $10,758, and $10,333 for tax              
          years 1995, 1996, and 1997, respectively, related to a property             
          in the Bahamas.  Petitioner claimed at trial that he held the               
          property for rental purposes, although he did not rent the                  
          property during the years at issue.  Further, petitioner did not            
          report income related to the property during the years at issue.            
          Petitioner failed to produce receipts and records to substantiate           
          his claims.                                                                 






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