- 15 - item; (2) petitioner’s estimate of the fair market value of each item immediately prior to the purported casualty; (3) copies of Internet catalog and web pages reflecting items petitioner claims to have lost in the purported casualty that were collected by petitioner in anticipation of litigation; and (4) petitioner’s self-serving testimony. This Court is not bound to accept a 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 her testimony or provide any substantiation to support her claimed amount of casualty loss, we find that 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 $19,068. 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. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011