- 6 - however, and therefore she does not have a receipt of mailing to corroborate her testimony. Respondent contends that petitioner has a history of failing to file tax returns or provide financial information, and, therefore, petitioner’s testimony is not credible. Respondent’s settlement officer testified that petitioner had tax liabilities for previous years that respondent had attempted to collect. Respondent’s records indicate that although petitioner proposed collection alternatives for those years, respondent rejected the proposals due to petitioner’s failure to file tax returns or provide financial information. Petitioner did not dispute the settlement officer’s testimony regarding the prior years’ tax liabilities. In addition, petitioner acknowledged that she filed her 2005 tax return late. On the basis of the record, we agree with respondent that petitioner has demonstrated a pattern of missing deadlines with respect to filing her tax returns and providing respondent with requested information. In the absence of corroborating evidence, we are not required to accept, and do not accept, petitioner’s self-serving testimony that she mailed the 2004 tax return and Form 433-F to respondent on November 28, 2005. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Madden v. Commissioner, T.C. Memo. 2006-4.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011