Thomas James Allen - Page 8

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          entitled to the claimed $403 deduction because that amount                  
          pertained to the automobile for which he was allowed an                     
          automobile expense deduction in the amount of $1,950, based upon            
          6,000 miles of business travel.  Respondent is sustained on this            
          issue.                                                                      
               Petitioner claimed a $1,300 legal and professional services            
          expense deduction on his 1998 Schedule C.  He explained that he             
          paid that to a friend of a friend to draw up a business plan that           
          would lead to the incorporation of an unexplained business that             
          petitioner intended to pursue.  There is no evidence in the                 
          record that petitioner had an incorporated business during the              
          years in issue.  Testimony may be sufficient as proof but in an             
          instance such as here, where the testimony is conclusory and                
          subject to doubt, it falls short of overcoming respondent’s                 
          presumption of correctness.  Hearn v. Commissioner, 36 T.C. 672             
          (1961), affd. 309 F.2d 431 (9th Cir. 1962).  We sustain                     
          respondent on this issue.                                                   
               Petitioner claimed a vehicle rent or lease deduction on his            
          1998 Schedule C.  He stated that he rented vans to transport                
          various items to his home from Chicago and Commerce, Georgia, to            
          sell.  Again, we are left with petitioner’s uncorroborated self-            
          serving testimony to substantiate the claimed deduction, which              
          this Court need not accept.  Sacks v. Commissioner, T.C. Memo.              
          1994-217, affd. 82 F.3d 918 (9th Cir. 1996); Niedringhaus v.                






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