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however, did not show that there was a large balance forward from
2001 that could be used to pay for expenses in 2002. Petitioner
claims that there was no large balance forward in her bank
account because shortly after she deposited the checks from
Jackson Rancheria, she withdrew the money. As part of the
initial audit questions, TCO Martin had asked whether petitioner
had cash on hand outside of her bank accounts. Petitioner’s
representative at that time gave no indication that petitioner
had a “cash hoard”.
It is well established that the Court is not required to
accept petitioner’s self-serving testimony in the absence of
corroborating evidence. See Niedringhaus v. Commissioner, 99
T.C. 202, 219 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77
(1986). Moreover, petitioner has the burden of proof. See Rule
142(a). Petitioner’s uncorroborated testimony is insufficient to
convince the Court she used her excess 2001 winnings rather than
unreported gross receipts from her flea market sales to pay for
her gambling losses in 2002.
Petitioner did not raise any issues with respect to the
remaining income and expense items that TCO Martin used in his
cash T analysis.
Accordingly, the Court accepts respondent’s conclusion from
his cash T analysis that petitioner had excess expenditures of
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