- 35 -
are section 280F(d)(4) “listed property”.24 These items, as
previously stated, require strict substantiation. Here,
petitioners failed to detail the expenses denied, the amounts of
those expenses, and the business purpose for those expenses. We
are not required to, and shall not, guess.
Petitioners have failed to substantiate sufficiently the
expenses claimed in excess of the amount respondent allowed in
the notice of deficiency. Furthermore, petitioner’s vague
testimony that all the expenses claimed were for business
purposes is not sufficient. “It is well settled that we are not
required to accept petitioner’s self-serving testimony in the
absence of corroborating evidence.” Jacoby v. Commissioner, T.C.
Memo. 1994-612 (citing Lerch v. Commissioner, 877 F.2d 624, 631-
632 (7th Cir. 1989), affg. T.C. Memo. 1987-295); see Geiger v.
Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg. per curiam
T.C. Memo. 1969-159; Niedringhaus v. Commissioner, 99 T.C. 202,
212 (1992). “There must be sufficient evidence in the record to
permit the Court to conclude that a deductible expense was
incurred in at least the amount allowed.” Jacoby v.
Commissioner, supra (citing Williams v. United States, 245 F.2d
559, 560 (5th Cir. 1957)) (emphasis added). To permit
24Petitioner testified that part of the deductions claimed
and disallowed were for computer equipment and cellular
telephone. See sec. 280F(d)(4)(A)(v); Vaksman v. Commissioner,
T.C. Memo. 2001-165; Nitschke v. Commissioner, T.C. Memo. 2000-
230.
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