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Commissioner, 62 T.C. 834, 837 (1974). Rather, a tax return is
merely a statement of the taxpayer’s claim; the return is not
presumed to be correct. Wilkinson v. Commissioner, supra at 639;
Roberts v. Commissioner, supra at 837; see also Seaboard
Commercial Corp. v. Commissioner, 28 T.C. 1034, 1051 (1957) (a
taxpayer’s income tax return is a self-serving declaration that
may not be accepted as proof of the deduction or exclusion
claimed by the taxpayer); Halle v. Commissioner, 7 T.C. 245
(1946) (a taxpayer’s return is not self-proving as to the truth
of its contents), affd. 175 F.2d 500 (2d Cir. 1949); Swayne
Lumber Co. v. Commissioner, 25 B.T.A. 335, 339-340 (1932) (an
entry on a tax return is not evidence that an expenditure was
actually made). Much the same may be said about a taxpayer’s
bookkeeping entries and self-generated financial statements. See
Doyle v. Mitchell Bros. Co., 247 U.S. 179 (1918); Geiger v.
Commissioner, 440 F.2d 688, 669 (9th Cir. 1971), affg. per curiam
T.C. Memo. 1969-159.
In view of the foregoing, we hold for respondent on this
issue.
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