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Petitioner claims he paid each worker, in cash, more than
the $600 reporting threshold of section 6041(a). However, he
failed to prepare or submit the required information returns to
the Internal Revenue Service. See sec. 1.6041-1(a)(1) and (2),
Income Tax Regs. Petitioner asserted that Mr. McKinney
maintained records of how much each person worked so each could
be paid, but petitioner did not produce any records to support
payments to his crew and did not call Mr. McKinney to testify at
trial.
We are not required to, and do not, accept petitioner’s
self-serving testimony without corroborating evidence. See
Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971),
affg. per curiam T.C. Memo. 1969-159; Lerch v. Commissioner, T.C.
Memo. 1987-295, affd. 877 F.2d 624 (7th Cir. 1989).
Mr. Burrell claimed that he earned $4,500 for working full
time for petitioner in 2001. The Court does not find this
testimony credible. Accordingly, Mr. Burrell’s testimony does
not corroborate petitioner’s testimony.
To the extent such payments of compensation were made,
petitioner did not produce adequate records. Mr. Burrell’s
failure to report the $4,500 he claims he was paid casts doubt on
whether any amounts were actually paid. Petitioner’s failure to
file information returns casts further doubt as to the
compensation payments. See Haeder v. Commissioner, T.C. Memo.
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