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interest in the restaurant, the purpose of the transfer of funds
to or on behalf of Wayanne, and interests purportedly owned by
his sons and parents. At one point he denied having created his
own Forms W-2, but later said he intended thereby to reflect the
personal expenses paid on his behalf from the MIT account. He
denied that he had charge accounts, but when confronted with
evidence, admitted that he did have cards with his name on them,
but said the accounts were in his wife's name. He could not give
the Court a straight answer to a simple question, such as "Why
did you not have a personal bank account in your own name?"
Moreover, petitioner's testimony was flatly contradicted by
Wilberding, an insurance agent (who testified that petitioner
represented that the house and car were his), and a revenue
agent. Although Mrs. Ferry was evasive, clearly trying hard to
avoid the twin pitfalls of perjury and contradicting her husband,
she did not corroborate his testimony. She said, for instance,
unbelievably, that she did not know who owned her house ("You'll
have to ask Don"), but admitted that she had no reason to believe
her brother owned it. She also testified that she had never seen
any gifts from petitioner's parents.
It is well settled that we are not required to accept a
taxpayer's self-serving testimony in the absence of corroborating
evidence, particularly where the testimony is unreasonable,
improbable, or questionable. Lerch v. Commissioner, 877 F.2d
624, 631-632 (7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger
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