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challenging the existence of his KD Fabricating business. Yet,
he produced no receipts or any other evidence, other than his own
testimony, of any customer payments to KD Fabricating. The Court
is not required to accept petitioner’s self-serving testimony,
particularly in the absence of corroborating evidence. See
Geiger v. Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg.
per curiam T.C. Memo. 1969-159; Urban Redev. Corp. v.
Commissioner, 294 F.2d 328, 332 (4th Cir. 1961), affg. 34 T.C.
845 (1960). The Court concludes that petitioner has not shown
that he was engaged in an activity for profit under the name KD
Fabricating in 2002.
Taxpayers are required to maintain records that are
sufficient to enable the Commissioner to determine the correct
tax liability. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Petitioner’s “substantiation” for claimed business expenses
consists of computer-generated listings of expenses entitled
“cash supplies”, “credit card expenses”, and “check schedule”.
Petitioner produced no original documents or copies of such items
as receipts, credit card records, bank statements, or canceled
checks, on which his computer records were supposedly based.
Petitioner’s cash expenditures as listed on his “cash supplies
document” totaled $31,468.49. Included in both the cash and
check expenses was the purchase of a new Toyota pickup truck for
$23,514.
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