Charles Y. and Jin Y. Choi - Page 16




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         the bank deposits analysis would have likely addressed any such              
         inclusion.  To the extent any cash from check cashing was a part             
         of the bank deposits analysis, it is unlikely that it is                     
         attributable to cash gifts from petitioner’s parents.                        
              We find the testimony offered on this point by petitioners              
         and their relatives to be self-serving, vague, and                           
         uncorroborated.  Petitioner’s parents could not recall the                   
         incremental amounts, dates, or total amount allegedly given to               
         petitioners and/or infused into Gene’s operation.  No gift tax               
         returns were filed by petitioner’s parents, and no record exists             
         of the alleged transfers.  Additionally, during the years under              
         consideration, petitioner supported his father and mother, both              
         of whom worked at Gene’s and lived under petitioners’ roof.  In              
         the absence of persuasive evidence and reliable corroboration, we            
         are not required to accept the self-serving testimony of                     
         interested parties.  See Tokarski v. Commissioner, 87 T.C. 74, 77            
         (1986).                                                                      
              Petitioners, in an attempt to discredit respondent’s                    
         reconstruction, offered their own reconstruction of income using             
         the percentage markup method.  They maintain that the percentage             
         markup method of reconstructing income would more accurately                 
         reflect petitioners’ income for the years in issue.  In                      
         particular, petitioners argue that a large percentage of the                 
         checks deposited and included in respondent’s bank deposits                  






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