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5T(c)(2)(i) through (iii), Temporary Income Tax Regs., 50 Fed.
Reg. 46017 (Nov. 6, 1985).
Petitioner argues that her claimed deductions have been
substantiated. Yet, the only evidence that petitioner has
submitted to this Court is her own self-serving testimony
regarding the deductions. We do not have to accept such
testimony without corroborating evidence. Niedringhaus v.
Commissioner, 99 T.C. 202 (1992). Further, aside from
petitioner’s argument that Mr. Rangel’s allowance of some
deductions is proof that her deductions were substantiated in
full, petitioner has not presented any corroborating evidence.
As such, petitioner does not meet the substantiation
requirements of section 162 or section 274(d). Accordingly, we
hold that petitioner did not substantiate her disallowed Schedule
C deductions and has, therefore, not shown respondent’s
determination to be in error.
II. Accuracy-Related Penalty of Section 6662(a)
Section 6662 provides for an accuracy-related penalty equal
to 20 percent of the underpayment if such underpayment was due to
taxpayer’s negligence or substantial understatement of income
tax. Sec. 6662(a) and (b)(1). For the purposes of this section,
a taxpayer is negligent when he or she fails “to do what a
reasonable and ordinarily prudent person would do under the
circumstances.” Korshin v. Commissioner, 91 F.3d 670, 672 (4th
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