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sented only their own uncorroborated and self-serving testimony
to support their contentions. We are not required to accept
their unsubstantiated testimony. Davis v. Commissioner, 88 T.C.
122, 141 (1987), affd. 866 F.2d 852 (6th Cir. 1989). We,
however, find no basis to credit Dr. Chan's vague and uncertain
testimony that he paid petitioner $15,000 in April and $10,000 or
$11,000 in September. Petitioners deny receiving these payments,
and Dr. Chan's testimony that they were paid was unconvincing.
Therefore, we find that petitioners received in 1990 $101,400 and
in 1991 $10,000 in unreported income as a result of petitioner's
teaching activity.
Petitioner also argues that, despite the fact that he
performed services for Dr. Chan, any money paid by Dr. Chan or
Shanghai Clinic was a gift to Yao Min Ting and Tang Chiang Ting.
Petitioners presented no evidence, other than their own self-
serving testimony, to support their gift theory. Petitioners
suggest that the amount of each payment, generally at least
$10,000, supports a determination that the payments were gifts
because it is unreasonable to pay someone such a large sum for
lessons. The Court finds no support for such an argument in the
record. Dr. Chan credibly testified that he believed the amounts
being paid for the lessons were reasonable in light of the
benefits that he received. These lessons took place between two
unrelated parties, and there is no evidence to support a conten-
tion that the fee arrangement was made at other than arm's
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