Salaheddin Ahmad Ahmad - Page 20

                                        -20-                                          
          similar deficiencies.  For example, petitioner testified that               
          during 1992, he often paid Saleh's rent, utilities, and other               
          expenses by check, and Saleh reimbursed him in cash.  This claim            
          is allegedly supported by a single check petitioner wrote to                
          Barnett Bank.19  Petitioner was unable to offer any evidence to             
          corroborate his claim of the purpose of the check, nor was he               
          able to produce evidence of a reimbursing cash deposit in the               
          amount of the check.  We find, therefore, that this check does              
          not corroborate petitioner's claims with respect to the funds               
          that he claimed are cash reimbursements of checks he wrote on               
          behalf of others.                                                           
               Petitioner relies on only his testimony to carry the burden            
          of proving the source of the balance of his deposits.20  Thus,              
          the issue is one of credibility wherein we must determine the               
          extent to which the proffered testimony is believable.  See Schad           
          v. Commissioner, 87 T.C. at 620.  It is well established that we            
          are not required to accept self-serving testimony in the absence            
          of corroborating evidence.  Niedringhaus v. Commissioner, 99 T.C.           


          19    A check drawn on petitioner's checking account in the                 
          amount of $2,328, made payable to Barnett Bank of Atlanta, was              
          entered into evidence.  Petitioner asserts this check was issued            
          to pay the balance due on Saleh's automobile.                               
          20     For example, petitioner testified he paid Gibson's                   
          personal bills, as well as her share of the household expenses,             
          by check, and she reimbursed him in cash.  Petitioner estimated             
          Gibson gave him $300 in cash each week for 17 weeks in 1992 and             
          for 52 weeks in 1993, all of which he deposited in his accounts.            
          This testimony is uncorroborated by any evidence.                           




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