- 23 - 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. RespondentPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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