Michael T. Hines - Page 5

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          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 has             

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