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and could not have negotiated the check. According to
petitioner, because respondent failed to rebut this contention by
producing the relevant canceled check from State Farm, the income
is not includable in his 1992 income. We disagree.
We consider it significant that the income now in dispute
was originally reported on petitioner’s 1992 return. Although
the circumstances surrounding the preparation and filing of that
return are less than routine, we are not persuaded that the items
of income shown on petitioner’s return are incorrect and reported
out of convenience, rather than correct and reported as required.
“Statements made on a tax return signed by the taxpayer have long
been considered admissions, and such admissions are binding on
the taxpayer, absent cogent evidence indicating they are wrong.”
Pratt v. Commissioner, T.C. Memo. 2002-279 (citing Waring v.
Commissioner, 412 F.2d 800, 801 (3d Cir. 1969), affg. T.C.
Memo. 1968-126; Lare v. Commissioner, 62 T.C. 739, 750 (1974),
affd. without published opinion 521 F.2d 1399 (3d Cir. 1975);
Rankin v. Commissioner, T.C. Memo. 1996-350, affd. 138 F.3d
1286 (9th Cir. 1998)). Disregarding petitioner’s self-serving
and uncorroborated testimony on the point, see Niedringhaus v.
Commissioner, 99 T.C. 202, 212 (1992), we find no cogent evidence
that petitioner erroneously included in his 1992 income the
income reported on the Form 1099 issued by State Farm.
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