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For the vast majority of the cash expenditures he seeks to
deduct, petitioner has no receipts or other records of the
expenditures. The only proof petitioner presents to evidence
these expenditures consists of his self-serving and
uncorroborated testimony. Under the circumstances, we are not
required to accept this testimony, and we do not. See Tokarski
v. Commissioner, 87 T.C. at 77; Shackelford v. Commissioner, T.C.
Memo. 1994-271. Thus, petitioner is not entitled to deduct these
expenditures.
As to those expenditures for which petitioner presented
receipts, he failed to present evidence of the business purpose
for each expenditure. Many of these expenditures appear to be of
a personal nature.
Accordingly, petitioner is not entitled to any of the
deductions sought for these expenditures.
10. Subscriptions
For 1991, petitioner seeks to deduct a $59 subscription
payment to a trade publication, Trade-A-Plane. Subscription
expenses with respect to trade and professional magazines
relating to a taxpayer’s trade or business are deductible under
section 162. See Kasey v. Commissioner, 54 T.C. 1642, 1650
(1970), affd. 457 F.2d 369 (9th Cir. 1972). In 1991, petitioner
was a licensed aircraft dealer engaged in the business of buying
and selling aircraft. On the basis of documentary evidence in
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