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times vague, evasive, inconsistent, and conclusory in his tes-
timony. In addition, based on our observation of petitioner's
demeanor at trial, we generally did not find him to be credible.
In these circumstances, we are not required to, and we generally
do not, accept petitioner's self-serving and uncorroborated
testimony. See Geiger v. Commissioner, 440 F.2d 688, 689-690
(9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159; Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.
593 (1964); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). We
generally found the other witnesses who testified to be credible.
A. The Adverse Inference Rule--
Mme. Koo's Failure To Testify
Mme. Koo, petitioner's mother-in-law, did not testify.
Petitioner claims on brief that she owned certain of the corpora-
tions (viz., Intercontinental, Double Wealth, Traveluck, Forward,
and Pioneer) that pledged cash deposits as security for a number
of the loans at issue.39 Citing Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir.
1947), respondent urges us to apply the so-called adverse
inference rule and to infer from petitioner's failure to call
Mme. Koo that her testimony would have been unfavorable to
petitioner. Relying principally on Wynn v. United States, 397
39 Petitioner also claims that during the years at issue Mme.
Koo and/or her family owned Vidda, a corporation to whose account
in Standard Chartered Bank HK certain interest due on certain of
the cash deposits that secured BB Loan Nos. 2 and 3 was credited.
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