- 17 - 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 permanentPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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