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a real estate loan business out of an office in La Jolla,
California, during 1992 and 1993. Together, petitioner and his
business associate subleased office space, consisting of four
offices and a conference room, from an attorney, according to
petitioner. Petitioner testified that his share of the $1,000
monthly office rental expense during 1992 and 1993 was $500.
Petitioner testified that he was unable to locate the attorney to
obtain any records of these rentals.
Petitioner's testimony concerning his office rental expenses
is uncorroborated and self-serving, and we are not required to
accept it. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
We do not, for a number of reasons.
First, we believe there were other opportunities for
corroboration that petitioner has not addressed, such as
testimony from the business associate who was purportedly his co-
lessee.
Second, we find petitioner's contention that the records for
his 1992 and 1993 business activities were discarded somewhat
suspect. Petitioner testified that the FBI seized his records in
1990, and his wife discarded them when they were returned in
1995. But the business activities at issue were conducted in
1992 and 1993. Even conceding that petitioner was under FBI
investigation during 1992 and 1993 (as his guilty plea occurred
in October 1994), we have some difficulty accepting petitioner's
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