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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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