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home or whatever, I said: ‘No’.” Petitioner finally testified
that he maintained a “Dome book”3 of bills and receipts during
the year, but did not produce it at the time of trial.
We find petitioner’s testimony and petitioners’ explanations
regarding the unexplained bank deposits to be self-serving and
not credible. We are not bound to accept such testimony or
explanations. See Shea v. Commissioner, 112 T.C. 183, 189
(1999). Indeed, we note that, despite their purported dislike
and distrust of banks, petitioners deposited over $65,000 of
wages and employee reimbursements into their bank accounts at
Quakertown National Bank. We are satisfied that respondent gave
petitioners proper credit for nonincome sources of deposits.
Accordingly, we sustain respondent’s determination.
2. Section 6662(a)
Respondent determined that petitioners are liable for the
accuracy-related penalty under section 6662(a) for 1995. The
accuracy-related penalty is equal to 20 percent of any portion of
an underpayment of tax required to be shown on the return that is
attributable to the taxpayer’s negligence or disregard of rules
or regulations. See sec. 6662(a) and (b)(1). “Negligence”
consists of any failure to make a reasonable attempt to comply
3 The origin of the term “Dome book” appears to be a book
entitled “Legal Deductions Allowable If You Are Engaged In A
Trade, Business or Profession” published by the Dome Publishing
Company in Providence, R.I. See United States v. Resnick, 483
F.2d 354, 356 n.3 (5th Cir. 1973).
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