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thereof. Sec. 6001; Meneguzzo v. Commissioner, 43 T.C. 824, 831-
832 (1965); sec. 1.6001-1(a), Income Tax Regs.; see Rule 142(a);
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v.
Helvering, 290 U.S. 111, 115 (1933); Segel v. Commissioner,
supra; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976); Goertler v. Commissioner,
T.C. Memo. 2003-136 (Commissioner’s position was substantially
justified as taxpayers had failed to substantiate deductions for
personal exemptions); see also sec. 7491(a)(2)(A) and (B). A
taxpayer’s self-serving declaration is no ironclad substitute for
the records that the law requires. See Weiss v. Commissioner,
T.C. Memo. 1999-17; see also Seaboard Commercial Corp. v.
Commissioner, 28 T.C. 1034, 1051 (1957) (a taxpayer's income tax
return is a self-serving declaration that may not be accepted as
proof for the deduction or exclusion claimed by the taxpayer);
Halle v. Commissioner, 7 T.C. 245, 247 (1946) (a taxpayer’s
return is not self-proving as to the truth of its contents),
affd. 175 F.2d 500 (2d Cir. 1949).
Factual determinations are required in order to decide
whether a taxpayer is entitled to: (1) Head of household filing
status, see sec. 2(b); (2) a dependency exemption deduction, see
secs. 151 and 152; (3) an earned income credit, see sec. 32; or
(4) a child tax credit, see sec. 24. We have held that whenever
the resolution of adjustments requires factual determinations,
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