Calvin L. Eubanks - Page 9




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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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