- 9 - testimony regarding his cost of sales other than his testimony that he paid his drivers in cash. Because we do not disturb respondent’s determination based solely on petitioner’s self-serving testimony that the Schedule C deductions claimed are correct and accurate, we sustain respondent’s determination disallowing petitioner’s Schedule C deductions. See Geiger v. Commissioner, T.C. Memo. 1969-159, (citing Halle v. Commissioner, 7 T.C. 245, 247 (1946), affd. 175 F.2d 500 (2d Cir. 1949)), affd. 440 F.2d 688 (9th Cir. 1971); see also Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (“we are not required to accept the self-serving testimony of petitioner * * * as gospel”). Section 6662 Accuracy-Related Penalty Section 6662 imposes an accuracy-related penalty upon any underpayment of tax resulting from negligence or disregard of the tax rules or regulations or from any substantial understatement of income tax. Negligence includes the failure of a taxpayer to keep proper records or to substantiate his reported expenses. Sec. 1.6662-3(b)(1), Income Tax Regs. The penalty does not apply, however, to any portion of the underpayment for which there was reasonable cause and with respect to which the taxpayer acted in good faith. Sec. 6664(c)(1); sec. 1.6664-4(b), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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