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Mr. Bonalewicz's testimony regarding the division of
proceeds is not credible.
Moreover, we note that petitioner has made numerous
inconsistent statements regarding the amount of money he
earned from the subject transaction. On July 25, 1990,
petitioner testified in the case of United States v.
Paul Nathaniel Hankish, CR 8900235, in the U.S. District
Court for the District of West Virginia, that he "ended up
with $1.5 million". During a November 6, 1991, meeting
with Revenue Agent Jeff Silva and his supervisor,
petitioner admitted that he earned a profit of $227,000 and
an additional $550,000 which he used to satisfy previously
incurred debt. On a third occasion, petitioner admitted to
Drug Enforcement Administration Agent John Peterson that he
and Mr. Lubiejewski made a net profit on several drug
smuggling operations, including the August 1983 transaction
in Michigan. At trial in the instant matter, however,
petitioner claimed that he did not earn any money from the
transaction.
We are not obligated to accept a taxpayer's self-
serving, improbable, uncorroborated testimony. See Quock
Ting v. United States, 140 U.S. 417 (1891); Geiger v.
Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg. per
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