George Maciel - Page 35

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          $30,283.07 for 1990, 1991, and 1992, respectively.  In support              
          thereof, petitioner proffers copies of checks from the “Alviso              
          Rock/HK Racing” bank account, copies of bank account statements,            
          and invoices.  No one other than petitioner testified about this            
          endeavor or the purported expenses.  From the evidence provided,            
          we are unable to determine whether the expenses detailed in the             
          invoices were for the benefit of petitioner’s racing business or            
          for one of his related businesses.  Nearly all the invoices are             
          made to “Alviso Rock”.                                                      
                         (ii).  Petitioner Does Not Sustain His Adjustments           
                              to Reconstructed Income                                 
               We are unable to sustain petitioner’s alleged unclaimed                
          expense deductions to the income that respondent reconstructed.             
          Petitioner fails to provide sufficient evidence to support the              
          expense deductions he claims for the years at issue.  Petitioner            
          failed to offer the testimony of any of the payees of his checks            
          to support his allegations.  The only evidence he has provided              
          are photocopies of checks, some invoices, and his trial                     
          testimony.  We find petitioner’s testimony self-serving, vague,             
          and not persuasive.  “It is well settled that we are not required           
          to accept petitioner’s self-serving testimony in the absence of             
          corroborating evidence.”  Jacoby v. Commissioner, T.C. Memo.                
          1994-612 (citing Lerch v. Commissioner, 877 F.2d 624, 631-632               
          (7th Cir. 1989), affg. T.C. Memo. 1987-295); see Geiger v.                  
          Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg. per curiam           





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