- 32 -
and $80 million in assets when Dixon bought it in 1981 and that
those assets had grown to more than $200 million when petitioner
returned to Dondi Financial in 1983. Petitioner also testified
that a monthly report submitted to the FHLBB showed that Vernon
had a positive net worth as of September 1986. While
petitioner's testimony is less reliable than Vernon's or Dondi
Financial's financial statements, we disagree with respondent's
view that we should disregard it.
e. Respondent's Other Contentions
Respondent points out that petitioner did not provide
documents or expert testimony to establish the amount of Vernon's
or Dondi Financial's liabilities for any year.
Petitioner testified to these points, but respondent urges
us to disregard his testimony as self-serving. We may not
arbitrarily disregard testimony that is competent, relevant,
credible, and uncontradicted. Conti v. Commissioner, 39 F.3d at
664; Ansley v. Commissioner, 217 F.2d 252, 257 (3d Cir. 1954);
Loesch & Green Constr. Co. v. Commissioner, 211 F.2d 210, 212
(6th Cir. 1954). We found petitioner's testimony to be credible
and uncontradicted. Respondent contends that we should infer
that any documentary evidence or testimony from prospective
witnesses would have been unfavorable to petitioner. Respondent
points out that where a party fails to introduce evidence in his
or her possession, which, if true, would be favorable, there is a
presumption that the evidence, if produced, would favor the
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