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he said. Petitioner testified that in moving from New York to
Puerto Rico he lost “nine boxes of documents”. He testified that
the amounts deducted on the return are estimates. Petitioner,
however, failed to explain how he arrived at his estimates.
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 his testimony or provide any substantiation
to support his itemized deductions, we sustain respondent’s
position with respect to the itemized deductions.
2. Schedule C Expenses
Section 162 generally allows a deduction for ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Generally, no deduction is
allowed for personal, living, or family expenses. See sec. 262.
The taxpayer must show, Rule 142(a), that any claimed business
expenses were incurred primarily for business rather than social
reasons, see Walliser v. Commissioner, 72 T.C. 433, 437 (1979).
To show that the expense was not for personal reasons, the
taxpayer must show that the expense was incurred primarily to
benefit his business, and there must have been a proximate
relationship between the claimed expense and the business. See
id.
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