- 48 -
We hold that petitioners' purported reliance on the other
partners at Shea & Gould, and in Alter's case Feinstein as well,
was not reasonable, not in good faith, nor based upon full
disclosure. Petitioners' testimony in these cases was self-
serving, and at times vague and elusive and this Court is not
required to accept it as true. Wood v. Commissioner, 338 F.2d
602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Niedringhaus
v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986); Snyder v. Commissioner, T.C.
Memo. 1995-285; Sacks v. Commissioner, T.C. Memo. 1994-217.
Moreover, petitioners' failure to call any of the Shea & Gould
partners to testify gives rise to the inference that their
testimony would not have been favorable to petitioners. Mecom v.
Commissioner, 101 T.C. 374, 386 (1993), affd. without published
opinion 40 F.3d 385 (5th Cir. 1994); Pollack v. Commissioner, 47
T.C. 92, 108 (1966), affd. 392 F.2d 409 (5th Cir. 1968); Wichita
Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946),
affd. 162 F.2d 513 (10th Cir. 1947); Sacks v. Commissioner,
supra.
The purported value of the Sentinel EPE recycler generated
the deductions and credits in these cases, and that circumstance
was reflected in the offering memoranda. Certainly Parker and
Feinstein recognized the nature of the tax benefits and, given
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