- 4 - tax return. The partnership agreement specifically provides that “The Partnership shall have a non-reimbursement policy when expenses are incurred outside the partnership.” There is no partnership provision requiring petitioner as a partner to pay partnership expenses from his own funds. Petitioner contends that he and his partner had a verbal agreement that petitioner would not seek reimbursement from the partnership for expenses he paid. Petitioner offered no evidence, other than his own oral testimony, that such an agreement existed or that he was required under such agreement to pay partnership expenses from his own funds. It is well established that this Court is not bound to accept a taxpayer’s self-serving, unverified, and undocumented testimony. Shea v. Commissioner, 112 T.C. 183, 189 (1999); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Whether or not petitioner ever made any alleged unreimbursed payments, petitioner was not required by the partnership agreement to make such payments, nor did petitioner prove there was a level of routine partnership practice tantamount to an agreement to do so. On this record, we conclude that petitioner is not entitled to deduct the unreimbursed partnership expenses in issue on his individual income tax return. We next consider whether petitioner is liable for the accuracy-related penalty under section 6662(a). Respondent hasPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011