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uncorroborated testimony that the five units “were damaged beyond
repair”. Petitioner did not support that assertion with any
pictures, documentary evidence, or the testimony of any third
party. We need not, and decline to, accept petitioner's
assertion at face value given his failure to corroborate. See,
e.g., Day v. Commissioner, 975 F.2d 534, 538 (8th Cir. 1992),
affg. in part, revg. in part T.C. Memo. 1991-140; Liddy v.
Commissioner, 808 F.2d 312, 315 (4th Cir. 1986), affg. T.C. Memo.
1985-107.
Respondent, however, presented the testimony of James
Bennett, the building official for the City of Mukilteo,
Washington, since July 1986 to the time of trial. Mr. Bennett
directed building inspection functions for the City of Mukilteo,
including structural nuisance inspections, abatement actions, and
condemnations. Mr. Bennett stated that no order of condemnation
was ever issued to any of the properties in the Mukilteo complex.
In addition, Mr. Bennett stated that, in 1996, when he visited
the Mukilteo complex, he observed that the buildings that housed
the individual condominium units were occupied and performing.
Petitioner did not attempt to refute any of Mr. Bennett's
statements. Indeed, petitioner has not been back to Mukilteo,
Washington, since the sale of the five units to Great Bank.
Mr. Bennett's testimony coupled with petitioner's failure to
rebut that testimony is inconsistent with petitioner's assertion
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