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secured the testimony of Mr. Nguon. Petitioner’s explanation is
unpersuasive.
Petitioner filed his petition on March 7, 2005, and the
Court’s notice setting case for trial on March 13, 2006, and
standing pretrial order were filed October 6, 2005. Petitioner
had over 1 year from the time of filing his petition and over 5
months after the case was set for trial to prepare his case. His
absence in the weeks leading up to trial does not excuse his
failure to prepare for trial. Additionally, petitioner testified
that he did not keep any business records. It is difficult to
understand how, if no records were kept, more time would have
allowed petitioner to produce additional documents to support his
testimony.
We do not find petitioner’s unsupported and self-serving
testimony to be credible. Niedringhaus v. Commissioner, 99 T.C.
202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77
(1986). Additionally, petitioner was deemed to have admitted
that the money received from Unwrapped was taxable income to him.
Therefore, we sustain respondent’s determination and find that
petitioner received but failed to report income of $447,084,
resulting in a deficiency in petitioner’s 2002 Federal income tax
of $171,823.
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