- 105 -
at 77; Bresler v. Commissioner, 65 T.C. 182, 188 (1975); Wichita
Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946),
affd. 162 F.2d 513 (10th Cir. 1947). We are not required to
accept petitioner’s self-serving testimony that his corporations
did not pay him rent. Frierdich v. Commissioner, supra; Liddy v.
Commissioner, 808 F.2d 312, 315 (4th Cir. 1986), affg. T.C. Memo.
1985-107; Laney v. Commissioner, 674 F.2d 342, 349-350 (5th Cir.
1982), affg. in part, revg. in part and remanding on another
issue T.C. Memo. 1979-491.
On the basis of the foregoing, we hold that petitioner has
not met the burden of proving that he did not have $12,425 in
unreported rental income from Air America in 1988.
Addition to Tax for Negligence Issue
In the notice of deficiency, respondent determined that
petitioner is liable for an addition to tax for negligence under
section 6653(a)(1) for 1988. In the amendment to answer to
amendment to petition, respondent alleged that petitioner was
liable for the addition to tax for negligence for the issues
raised in the amendment to answer.
Section 6653(a)(1) imposes an addition to tax equal to 5
percent of the underpayment if any part of the deficiency was due
to negligence or intentional disregard of rules or regulations.
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