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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,
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