                         T.C. Memo. 1999-329



                       UNITED STATES TAX COURT



               DONALD FRANCIS COOK, Petitioner v.
          COMMISSIONER OF INTERNAL REVENUE, Respondent



     Docket No. 23276-97.              Filed September 30, 1999.



     Donald Francis Cook, pro se.

     Kenneth C. Peterson, for respondent.



                         MEMORANDUM OPINION


     CHIECHI, Judge:    Respondent determined the following defi-

ciencies in, and accuracy-related penalties under section

6662(a)1 on, petitioner's Federal income tax:



     1
      All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
                               - 2 -


  Year         Deficiency              Accuracy-Related Penalty
  1994           $12,258                        $2,451
  1995            14,219                         2,843

     We must decide whether the determinations in the notice of

deficiency (notice) for each of the years at issue that have not

been conceded by respondent should be sustained.    We hold that

they should.

     Some of the facts have been stipulated and are so found.      On

November 9, 1998, respondent filed a request for admissions with

the Court, a copy of which respondent had served on petitioner on

November 4, 1998.   Petitioner did not file any response to that

request.   As a result, each matter set forth in respondent's

request for admissions is deemed admitted.    See Rule 90(c);

Marshall v. Commissioner, 85 T.C. 267, 272 (1985).

     Petitioner resided in Lake Forest, California, at the time

he filed the petition.

     During the years at issue, petitioner was self-employed as a

building contractor.   Petitioner filed Form 1040, U.S. Individual

Income Tax Return, for each of the years 1994 and 1995.    Peti-

tioner reported certain income and claimed certain expenses from

his activities as a building contractor in Schedule C of Form

1040 (Schedule C) for each of those years.

     In the notice issued to petitioner, respondent made adjust-

ments to certain items of income and expense that petitioner
                               - 3 -


reported in Schedule C for each of the years 1994 and 1995 and

corresponding adjustments to petitioner's self-employment tax for

each of those years.   Respondent also determined in the notice

that petitioner is liable for the accuracy-related penalty under

section 6662(a) for each year at issue.

     Petitioner bears the burden of proving that the determina-

tions in the notice are erroneous.     See Rule 142(a); Welch v.

Helvering, 290 U.S. 111, 115 (1933).     Petitioner attempted to

satisfy that burden through his self-serving testimony, which was

largely general, vague, irrelevant, and/or conclusory.     We are

not required to, and we shall not, rely on that testimony.     See

Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),

affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,

689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;

Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).

     We have considered all of the arguments and contentions of

petitioner, and we find them to be without merit and/or irrele-

vant.   Based on our examination of the entire record in this

case, we find that petitioner has failed to satisfy his burden of

showing error in any of the determinations in the notice that

have not been conceded by respondent.

     To reflect the foregoing and the concessions of respondent,


                                       Decision will be entered under

                               Rule 155.
