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claimed deductions. INDOPCO, Inc. v. Commissioner, 503 U.S. 79,
84 (1992). A taxpayer must keep records adequate to allow the
Commissioner to establish the amount of his deductions. See sec.
6001; sec. 1.6001-1(a), Income Tax Regs. A taxpayer must also
produce those records upon request for inspection by authorized
internal revenue officers or employees. Sec. 7602(a); sec.
1.6001-1(e), Income Tax Regs. We are not required to accept an
interested party’s self-serving testimony that is uncorroborated
by persuasive evidence. See Tokarski v. Commissioner, 87 T.C.
74, 77 (1986).
Petitioners’ position throughout this case has been that
they have adequately substantiated their Schedules A, C, and F
expenses because they stated under oath that the expenses were
correct. That position is wrong, and we reject it. Petitioners
had an obligation to substantiate their deductions in the manner
required by the Code. Sec. 6001; sec. 1.6001-1(e), Income Tax
Regs. Petitioners also had an obligation to produce the required
records upon request by respondent. Sec. 7602(a). The
affidavits were not sufficient to satisfy petitioners’
affirmative obligation under sections 6001 and 7602 to keep
records substantiating their deductions and to produce those
records to respondent upon request. See, e.g., Kolbeck v.
Commissioner, T.C. Memo. 2005-253.
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