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section 481(a) adjustment.12 Petitioner contends that he made
similar agreements with other office managers but is unable to
provide copies of them. Petitioner did not produce any of the
office managers as witnesses at trial to corroborate his
testimony. Petitioners acknowledge that we are not bound to
accept petitioner's uncorroborated testimony. Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir.), affg. 41 T.C. 593
(1964).
The agreement in evidence that was in effect at the relevant
times, which pertains to the Vallejo office of petitioner's
business, contains, inter alia, the following provisions: (1) A
pledge of collateral by the office manager, referred to in the
agreement as a bail agent, to secure payment to petitioner of
losses incurred by the manager; (2) an agreement to share equally
the profits of "James Rankin Bail Bonds" between petitioner and
the manager; and (3) an agreement that the two "will share the
separate reserve for the Vallejo office". The agreement does not
further specify the nature of sharing intended by the parties or
the manner in which it is to be effected. The agreement is
otherwise ambiguously drafted in that it suggests that all
profits made by James Rankin Bail Bonds, which, based upon the
Schedules C in petitioners' 1987 and 1988 returns, appears to be
a business operation different from the bail bond operation
12 The other agreement was dated Sept. 1, 1988, and concerns
the same office as the first agreement.
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