- 11 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007