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not required to accept petitioner's self-serving testimony as
true, particularly when inconsistent and contradicted by other
evidence. 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, supra.
Petitioner does not allege that Tucker misled or deceived
him. As a member of Becker Co., Tucker was privy to the
particulars of Becker's investigation. Certainly he knew that
Becker did not take any experts with him to PI, especially
considering Becker's testimony that Tucker was with him on one
such occasion. To the extent that Tucker related the particulars
of Becker's investigation to petitioner, we have no reason to
doubt that his representations were accurate and forthright. In
addition, Becker's testimony convinces us that petitioner
discussed the Plastics Recycling transactions with Becker and
that Becker supplemented the representations made by Tucker, so
that petitioner knew "precisely what * * * [Becker] had done to
investigate or analyze the transaction." Accordingly, we find
that petitioner was fully apprised of the particulars of Becker
Co.'s investigation, consistent with the facts as we have found
them.
We hold that petitioner's purported reliance on Tucker, and
indirectly on Becker, was not reasonable, not in good faith, nor
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