Carey K. Parker II - Page 7

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               Respondent relies on the Web site certified mail document,             
          the certified mail list, and the literal transcripts to establish           
          that on September 2, 2003, petitioner was mailed, via certified             
          mail, a hearing notice for 1994, 1995, 1996, and 1997 to the                
          Shorewood address.  Petitioner admitted that the address listed             
          on the Web site certified mail document and certified mail list             
          is, and was in September 2003, his correct address.  The Web site           
          certified mail document, the certified mail list, and the literal           
          transcripts are consistent and corroborate that respondent mailed           
          petitioner, via certified mail, the hearing notice no later than            
          September 2, 2003.                                                          
               Petitioner claims that he did not receive the hearing                  
          notice.  Petitioner’s testimony is inconsistent with the                    
          documentary evidence in the record.  Orum v. Commissioner, 123              
          T.C. 1, 9 (2004), affd. on other grounds 412 F.3d 819 (7th Cir.             
          2005).  The Court is not required to accept petitioner’s                    
          unsubstantiated testimony.  See Wood v. Commissioner, 338 F.2d              
          602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964).  The Court              
          need not accept at face value a witness’s testimony that is self-           
          interested or otherwise questionable.  See Archer v.                        
          Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a                    
          Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d           
          152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v.            
          Commissioner, T.C. Memo. 1986-467.  After observing petitioner’s            






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