- 9 - to leading questions by his counsel, and his testimony on cross- examination was vague and evasive. Petitioners argue that a different result in this case would have followed if respondent had interviewed J. Mantakounis prior to his death regarding the loan. Presumably, petitioners believe that J. Mantakounis’s testimony would have proved the existence of the loan. We are not required, however, to accept self- serving, unverified, and uncorroborated statements of petitioner or of his parent. Tokarski v. Commissioner, 87 T.C. at 77; see Cluck v. Commissioner, 105 T.C. 324, 338 (1995). Considering the belated and inconsistent explanations provided by petitioner before and during trial, we do not accept his testimony. We uphold respondent’s determination that the $105,000 was unreported income. Addition to Tax and Penalty Respondent determined an addition to tax for failure to file timely under section 6651(a)(1) and an accuracy-related penalty for substantial understatement under section 6662(a). Petitioners have presented neither evidence nor argument regarding the addition to tax and penalty. Respondent determined the addition to tax for late filing because, although petitioners were granted an extension to file until October 15, 1992, they did not file until January 21, 1993. To escape the addition to tax for filing late returns,Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011