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testified that she visited CRC once or twice a week, reviewed
CRC’s records, and recorded any shareholder advances taken by
Tony or Robert. Respondent placed in evidence summary sheets
prepared by Conley, McDonald & Sprague, which reflect the amounts
Tony owed on his shareholder account. These sheets indicate that
when Tony’s CRC shares were redeemed, Tony owed CRC $116,831.
Other than Tony’s bald insinuation of impropriety in CRC’s
record keeping, petitioners have given us no reason to doubt the
validity of Conley, McDonald & Sprague’s summary sheets. We
found Tony’s testimony to be vague, uncorroborated, and
conclusory in certain material respects. Under these
circumstances, we are not required to, and we do not, accept
Tony’s testimony. See Lerch v. Commissioner, 877 F.2d 624, 631-
632 (7th Cir. 1989), affg. T.C. Memo. 1987-295; Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986).
In sum, the evidence establishes that petitioners realized
$166,831 from Tony’s disposition of his CRC stock. Petitioners
have failed to establish any basis in the stock. Accordingly, we
conclude that they had a $166,831 capital gain from the stock
redemption, and we sustain respondent’s determination that
petitioners underreported their capital gains by $116,831.
B. Tony’s Stock Car Activity
Under section 183(b)(2), if an individual engages in an
activity not for profit, deductions relating thereto are
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