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petitioner attributed the entire reported amount, $28,248, to the
Johnsons' default.
Petitioner testified that in selling the house to the
Johnsons, he took back a second mortgage of approximately
$33,000, which was payable in three annual installments, and that
the Johnsons defaulted after making the first payment.
Petitioner further testified that he pursued collection of the
debt owed him by the Johnsons, and that he obtained a $40,000
judgment against Ben and a $20,000 judgment against Kathy, which
he recorded in the counties where the Johnsons now reside.
Petitioner relies on only his testimony to carry the burden
of proving the loss; he failed to produce any corroborating
evidence to support his testimony. 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. 609, 620 (1986), affd. without published opinion 827 F.2d
774 (11th Cir. 1987). 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.
202, 212 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
Moreover, the rule is well established that the failure of a
party to introduce evidence within his possession and which, if
true, would be favorable to him, gives rise to the presumption
that if produced it would be unfavorable to him. Wichita
Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946),
affd. 162 F.2d 513 (10th Cir. 1947). This is particularly true
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