- 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 Next
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