- 28 -
important respects, Teresa has failed to tell the truth. For
example, we believe that, with respect to her dealings with the
Internal Revenue Service in 1986, she has failed to tell the
truth. Accordingly, we have accorded Teresa's testimony and
answers little weight. Cf. Gerardo v. Commissioner, 552 F.2d
549, 553 (3d Cir. 1977), affg. in part and revg. in part T.C.
Memo. 1975-341, (Tax Court need not give credence to testimony
that it disbelieves). Tracy did testify orally. In important
respects, her testimony was vague and indefinite. She was
contradicted by other witnesses. We do not have much confidence
in her testimony, and, accordingly, we give it little weight.
E. Conclusions
We have concluded that the daughters are taxable on the
proceeds of the $2 million notes and that Parker is not. See
supra sec. I.D.1. That conclusion is based on our finding that
Parker made gifts to the daughters no later than January 26,
1980, of some or all of his rights under the earnest money
contracts. Id. The daughters have argued that there were no
gifts in 1980. They have not, however, argued that, if we were
to find gifts in 1980, respondent’s adjustments for 1985
increasing each daughter’s taxable income by $725,188 otherwise
were in error. Accordingly, we believe that the daughters have
conceded the amounts of taxable income that result from our
finding that Parker made gifts to them no later than January 26,
1980. We so find.
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011