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supra; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976); see also sec. 7491(a)(2)(A)
and (B). A taxpayer’s self-serving declaration is no ironclad
substitute for the records that the law requires. See Weiss v.
Commissioner, T.C. Memo. 1999-17; see also Seaboard Commercial
Corp. v. Commissioner, 28 T.C. 1034, 1051 (1957) (a taxpayer's
income tax return is a self-serving declaration that may not be
accepted as proof for the deduction or exclusion claimed by the
taxpayer); Halle v. Commissioner, 7 T.C. 245, 247 (1946) (a
taxpayer’s return is not self-proving as to the truth of its
contents), affd. 175 F.2d 500 (2d Cir. 1949).
Factual determinations are required in order to decide
whether a taxpayer is entitled to: (1) Head-of-household filing
status, see sec. 2(b); (2) a dependency exemption deduction, see
secs. 151 and 152; or (3) an earned income credit, see sec. 32.
We have held that whenever the resolution of adjustments requires
factual determinations, the Commissioner is not obliged to
concede those adjustments until the Commissioner has received,
and has had a reasonable period of time to verify, adequate
substantiation for the matters in question. Gealer v.
Commissioner, T.C. Memo. 2001-180, and cases cited therein;
O’Bryon v. Commissioner, T.C. Memo. 2000-379, (and cases cited
therein); Cooper v. Commissioner, T.C. Memo. 1999-6.
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