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undocumented testimony. Tokarski v. Commissioner, 87 T.C. 74, 77
(1986).
Smith issued a Form 1099 stating that Ms. Potter received
$3,038 in 1999. Ms. Potter testified that she was not
compensated by Smith for her involvement in the after-school
program. She does, however, admit to receiving "reimbursement
checks". Other than their testimony, petitioners have presented
no evidence to substantiate their position that the money from
Smith represented reimbursements for Ms. Potter's out-of-pocket
expenses. Ms. Potter testified that the checks from Smith were
"to cover the cost of the advertising and the, the copying costs,
the color copying costs, of all the programs that I was trying to
run." She claims to have given the receipts to a secretary, and
that a treasurer of the Smith PTO wrote the reimbursement checks.
Mr. Palomo testified that when preparing their Federal income tax
return he ignored the Form 1099 petitioners received because,
based on his mental calculations, "it was going to be a wash."
In a prior hearing before this Court, Mr. Palomo agreed to
do his best to provide names, telephone numbers, and addresses of
people involved with the Smith PTO. At no point, however, did
petitioners provide the name or names of anyone at Smith to
verify their claims.
Petitioners have not provided either the Commissioner or
the Court with any evidence substantiating the existence of out-
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