W. Bradford Davis and Tedde M. Rinker - Page 8

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                    This case epitomizes the ultimate task of a trier                 
               of the facts--the distillation of truth from falsehood                 
               which is the daily grist of judicial life.  He must be                 
               careful to avoid making the courtroom a haven for the                  
               skillful liar or a quagmire in which the honest                        
               litigant is swallowed up.  Truth itself is never in                    
               doubt, but it often has an elusive quality which makes                 
               the search for it fraught with difficulty.  That this                  
               is so is clearly illustrated by the situation herein.                  
               * * *                                                                  
               We decide whether a witness is credible on the basis of                
          objective facts, the reasonableness of the testimony, and the               
          demeanor of the witness.  Quock Ting v. United States, 140 U.S.             
          417, 420-421 (1891); Wood v. Commissioner, 338 F.2d 602, 605 (9th           
          Cir. 1964), affg. 41 T.C. 593 (1964); Dozier v. Commissioner,               
          T.C. Memo. 2000-255.                                                        
               From our observation of petitioners at trial, we found Dr.             
          Rinker’s testimony on this point to be credible, sufficiently               
          detailed, and reasonable.  Dr. Rinker’s demeanor on the stand was           
          forthright and earnest.  While petitioners at times lacked                  
          detailed memories of some of their financial activities in 1999,            
          Dr. Rinker recalled her meeting with Mr. Hertz at her house in              
          2002 with relative precision.  She testified that at the                    
          conclusion of that meeting, she gave Mr. Hertz a box containing             
          the bulk of her source documents, and that she never saw them               
          again.                                                                      
               Mr. Hertz testified that he gave the box of records back to            
          Dr. Rinker at the conclusion of that meeting.  According to Mr.             
          Hertz’s testimony, the entire purpose of the meeting was to                 





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