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petitioner must establish that his Sherman Oaks Property rent
payments were incurred in carrying on his trade or business.
Petitioner has not shown that he ever conducted his medical
practice at Sherman Oaks Property. The only evidence petitioner
offered was his own self-serving testimony that he had an oral
agreement with his brother and that he saw patients at Sherman
Oaks Property in 1991 and 1992. As we do not need to accept
self-serving testimony without corroborating evidence, this
testimony, by itself, is not enough to establish that petitioner
conducted business activity at the Sherman Oaks Property during
1994 and 1997. Niedringhaus v. Commissioner, 99 T.C. 202 (1992).
Further, even if we accepted petitioner’s testimony, it does not
relate to business activity at the Sherman Oaks Property for the
1994 and 1997 tax years. Petitioner offers no evidence
indicating that he conducted his medical practice at the Sherman
Oaks Property in either 1994 or 1997.
Many facts, however, indicate an absence of business
activity by petitioner at the Sherman Oaks Property during the
years at issue. Petitioner did not take any of the customary
steps of starting up a medical practice at Sherman Oaks Property
that he had taken in Riverside County. Petitioner did not
acquire business permits or licenses, did not maintain any type
of local telephone listing, did not have any local hospital
privileges, and was not a member of the Los Angeles County
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