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that she took the settlement money along with money from the
paychecks of Michoff, Sr., and hid them from Michoff, Sr. The
funds that she used allegedly came from a personal injury
settlement of Michoff, Sr., as well as the paychecks of Michoff,
Sr., which were made out to him and which he picked up at work.
We find it unlikely that Beverly Michoff could have taken these
funds and hid them from Michoff, Sr., for so many years.
Additionally, Beverly Michoff testified that her husband did not
believe in banks. However, during the years in issue the
Michoff, Srs., actively used savings accounts, credit card
accounts, and a credit union account. Under all the
circumstances, we are not required to accept the self-serving
testimony of petitioner. Tokarski v. Commissioner, 87 T.C. at
77. Based on our review of the record and the circumstances, we
find Beverly Michoff's explanation of a cash hoard not to be
credible.
The explanations of the Michoff, Srs., as to their other
deposits and expenditures which are at issue are equally lacking
in credibility. They seek to rely on uncorroborated testimony
and unsupported argument. This is not sufficient evidence to
meet their burden of proof. The Michoff, Srs., have failed to
prove that any of the amounts at issue are from nontaxable
sources.
As a source of additional income, respondent identified the
transactions of the Michoff, Srs., with their son. Respondent
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