Edward C. Rosa - Page 5

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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             

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