Chong-Kak and Sang-Ok Lee - Page 15

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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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