Michael Chin and Julie Hedrich Chin - Page 8




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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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