22
Petitioner testified that he initially invested $10 per
share, and that he did not know how much he invested or where he
got the funds to invest. Petitioner's testimony was evasive,
vague, and not credible. He seemed to have selective recall. He
was inexplicably unable to remember basic details about his
investment in Bohannon, S.A., when it was incorporated, the
identity of its initial shareholders,5 and how he set the selling
price of his stock. Petitioner testified that he did not know
where Bohannon, S.A. is located or how the corporate bills were
paid, despite the fact that he said he incorporated it and that
he is president of the corporation and was a major shareholder
until the mid-1960's. We need not accept self-serving testimony.
Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971),
affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). Kane saw no records of petitioner's stock
sale or basis in the stock; he saw only petitioner's handwritten
notes.
Petitioners submitted no documentary evidence at trial to
establish their basis in Bohannon, S.A. Under these
circumstances, we do not consider petitioner's estimate of basis.
5 Bob Wade testified that petitioner incorporated Bohannon,
S.A. with Mrs. Bohannon's father and brother. We find it
incredible that petitioner cannot remember with whom he
incorporated the corporation.
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