Oliver E. Stubblefield - Page 16

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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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