Nick Kikalos and Helen Kikalos - Page 17

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          Petitioner did verify that $6,569 in bulk sales was included in             
          income.  Respondent conceded the $6,569 so that $18,856 remains             
          in dispute.                                                                 
               Petitioner argues his combination of substantiation of                 
          $6,569 in bulk sales and the testimony offered about the                    
          procedures employed for recording bulk sales is sufficient to               
          show that all bulk sales were properly recorded.  Petitioner also           
          argues that the burden of reviewing a large amount of register              
          tapes was too great to substantiate all bulk sales transactions.            
               Despite having access to records that could substantiate all           
          bulk sales, petitioner failed to offer this evidence.  Petitioner           
          had register tapes available, and self-serving testimony does not           
          suffice to satisfy petitioner’s burden.  We are not required to             
          accept such testimony.  Niedringhaus v. Commissioner, 99 T.C.               
          202, 212 (1992).  Accordingly, we hold that petitioner failed to            
          report $18,856 of bulk sales income, the amount of respondent’s             
          determination net of concessions.                                           
          IV.  Vendor Refunds and Reimbursements Income                               
               Respondent also determined that $3,007 in third party checks           
          used to purchase cashier’s checks was attributable to vendor                
          refunds and reimbursements not included in petitioner’s 1997                
          gross income.  Petitioner argues that the payments were included            
          in income, but he has not provided any records to substantiate              
          these assertions.  Taxpayers are required to keep permanent                 






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