- 8 - 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 CountyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011