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account to secure a higher interest rate.1 On the withdrawal
form, Mr. Anderson checked the box for normal distribution but
handwrote “rollover” in the same section. Upon receipt of the
check, Mr. Anderson went to Northwest National Bank of Arlington
(Arlington) and stated that he wanted to open an account with his
IRA check.2 The new accounts representative at Arlington advised
Mr. Anderson that he might want to open up two accounts, one for
himself and one for his wife, in order to maximize the insurance
coverage of the Federal Deposit Insurance Corporation (FDIC) on
their accounts.3 With the proceeds of his IRA check, Mr.
Anderson purchased from Arlington a 1-year, $100,000 Certificate
1 Each year, Mr. Anderson had withdrawn the income earned on
the account. The record does not explain the $17,158.86
difference between the deposited funds and the withdrawn balance.
2 Although petitioners testified summarily that they
specifically asked the representative to open an IRA account for
them, we find this testimony unbelievable in light of the record
as a whole. We decline to rely on that naked, self-serving
testimony for the purpose of reaching our decision herein. See
Commissioner v. Duberstein, 363 U.S. 278, 291 (1960); Casperone
v. Landmark Oil & Gas Corp., 819 F.2d 112, 115 (5th Cir. 1987);
Diamond Bros. Co. v. Commissioner, 322 F.2d 725, 731 (3d Cir.
1963), affg. T.C. Memo. 1962-132. Petitioners could have, but
did not, call as a witness the representative of the bank to
testify as to her memory of the conversation. (Mrs. Anderson
testified that the bank president disputed petitioners’ claim
that the bank had erroneously not opened an IRA account.) We
also note, as described infra, that Mr. Andersen is a college-
educated man who we believe would have noticed that the
application opening the account was not in the name of an IRA nor
was creating a trust account.
3 The representative advised Mr. Anderson that the FDIC
insured each account of a depositor up to a maximum of $100,000.
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