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documents showing that the Lees hired a law firm allegedly to
recover Hamalee's stolen property, and that the firm sent a
letter to both Mr. Won and his brother in May 1990, asking them
to compensate Hamalee for the thefts or face criminal prosecution
if they did not. When the letters received no response, the
witnesses testified, no further action was taken to recover the
allegedly stolen amounts.
We are not persuaded by petitioners' arguments. Simply put,
they have failed to show us that the Lees did not actually or
constructively receive these distributions. Petitioners rely
mainly on the testimony of the Lees and numerous "family" members
to support their allegations for a contrary result. We give this
testimony little weight. In addition to the fact that much of it
is self-serving and/or biased, we find that none of the relevant
testimony is corroborated by uninterested persons or any other
reliable evidence. Under the circumstances, we are not required
to, and we do not, rely on that testimony to support petitioners'
positions herein. LaBow v. Commissioner, 763 F.2d 125, 131 (2d
Cir. 1985), affg. in part and revg. in part on other grounds T.C.
Memo. 1983-417; Lifschultz v. Commissioner, 393 F.2d 232, 234 (2d
Cir. 1968), affg. T.C. Memo. 1966-225; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986).
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