Narvell Darling - Page 11

                                       - 11 -                                         
          taxpayer’s unverified and self-serving testimony.  Blodgett v.              
          Commissioner, 394 F.3d 1030, 1036 (8th Cir. 2005), affg. T.C.               
          Memo. 2003-212; Shea v. Commissioner, 112 T.C. 183, 189 (1999).             
          Because petitioner has failed to corroborate his testimony or               
          provide any substantiation to support his claimed amount of                 
          casualty loss, we find we cannot estimate any amounts of                    
          petitioner’s deductions under the Cohan rule, and we sustain                
          respondent’s disallowance of petitioner’s claimed casualty loss             
          deduction in the amount of $35,410.                                         
               We have considered all of the other arguments made by the              
          parties, and, to the extent that we have not specifically                   
          addressed them, we conclude they are without merit.                         
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        for respondent.                               




















Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  

Last modified: May 25, 2011