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credibility. Petitioner's testimony lacked the ring of truth,
and Ms. Rawls' testimony sounded rehearsed. In short, we do not
find the testimony of petitioner and Ms. Rawls to be worthy of
belief. Under these circumstances, we are not required to, and
we generally do not, accept either petitioner's self-serving
testimony or what we regard as Ms. Rawls' programmed testimony.
See Tokarski v. Commissioner, supra; Hawkins v. Commissioner,
T.C. Memo. 1993-517, affd. without published opinion 66 F.3d 325
(6th Cir. 1995).10
In view of our negative assessment of the credibility of
petitioner and Ms. Rawls, we find it unnecessary to painstakingly
dissect and analyze the record in this case. See Hawkins v.
Commissioner, supra. Rather than immediately moving on to the
next issue, however, we think it appropriate to make a few
comments and observations in order to illustrate why, independent
of our assessment of credibility, we find the record in this case
to be deficient from petitioner's point of view.11
10 In Hawkins v. Commissioner, T.C. Memo. 1993-517, affd.
without published opinion 66 F.3d 325 (6th Cir. 1995), we stated
as follows:
As is customary in this Court, we have treated
petitioners with respect and viewed their * * * story
in an unbiased manner. Although petitioners' story is
imaginative, we find it * * * unbelievable.
11 As a preliminary matter, we note that statements made in
briefs do not constitute evidence. Rule 143(b).
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