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the damage to his residence, but could not remember the exact
amount. While we are permitted to estimate the amount of a
deduction under certain circumstances, there must be evidence in
the record upon which to base our decision. Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930). Petitioner did not
corroborate his testimony with any evidence whatsoever to
establish the $4,000 figure. It is well settled that we are not
required to accept a taxpayer’s self-serving testimony in the
absence of corroborating evidence. Niedringhaus v. Commissioner,
99 T.C. 202, 212 (1992).
Petitioner presented receipts totaling only $2,588.01 for
labor and materials to replace the roof and received $857.12 in
insurance proceeds. Therefore, only the $1,730.88 of net expense
corroborated by documentary evidence is considered in determining
petitioner’s casualty loss deduction.
We need not determine on the merits if petitioner has met
the four substantiation requirements of section 1.165-
7(a)(2)(ii), Income Tax Regs., because petitioner’s net expense
is less than the amount of the section 165(h) limitations.
Applying the section 165(h) limitations, petitioner’s net expense
of $1,730.88 minus the $100 limitation, or $1,630.88, is far less
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