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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.
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