David E. Benson - Page 16




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          introduce evidence regarding reasonable cause * * * or similar              
          provisions. * * * the taxpayer bears the burden of proof with               
          regard to those issues.”  Id.                                               
               Petitioner conceded certain determinations that respondent             
          made in the notice.  As a result, petitioner has acknowledged               
          that an underpayment exists for his taxable year 1999.                      
               With respect to the accuracy-related penalty under section             
          6662(a) that respondent determined for petitioner’s taxable year            
          1999, petitioner testified:                                                 
               I keep as accurate records as I always have.  I use a                  
               computer program to do my taxes.  I’m pretty precise                   
               about what I put in there and back it up to the best of                
               my ability.  I’ve done this for 30 years.  Well, not                   
               computerized, but I’ve used a computer since 1988 doing                
               my taxes.                                                              
                        *     *     *     *     *     *     *                         
                    * * * I always go through it, the computer program                
               will check it for any discrepancies, and even then I                   
               will go back through it and check it again.  So all the                
               calculations are done by the computer, but I do double-                
               check, and the computer will flag anything that is a                   
               discrepancy.                                                           
               The record in this case does not contain any of the records            
          that petitioner testified he maintained.  We are not required to,           
          and we shall not, accept petitioner’s uncorroborated, self-                 
          serving, and conclusory testimony about maintaining records.  See           
          Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),               
          affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,            
          689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;              







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