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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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