Glenyce R. Peterson - Page 13

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          cashed in various life insurance policies during 1990.  The                 
          proceeds from such loans and insurance policies, petitioner                 
          contends, more than account for the imbalance between the                   
          couple's earnings and expenditures for taxable year 1990.  At               
          trial, however, when questioned whether she could substantiate              
          such allegations, petitioner explained that, although she                   
          possessed documentary proof of the above-referenced loans, she              
          had not brought such documentation to court.  Moreover, other               
          than her own testimony, petitioner did not offer any                        
          corroboration for her assertion regarding the life insurance                
          policies allegedly cashed in by her former husband.  Although               
          petitioner's testimony regarding the loans and life insurance               
          policies was not contradicted at trial, we are not required to              
          accept petitioner's self-serving testimony if we determine it to            
          be improbable or questionable.  Lovell & Hart, Inc. v.                      
          Commissioner, 456 F.2d 145, 148 (6th Cir. 1972), affg.  T.C.                
          Memo. 1970-335; MacGuire v. Commissioner, 450 F.2d  1239, 1244              
          (5th Cir. 1971), affg.  T.C. Memo. 1970-89; Tokarski v.                     
          Commissioner, 87 T.C. 74, 77 (1986); see also Lerch v.                      
          Commissioner, 877 F.2d 624 (7th Cir. 1989); Shapiro v. Rubens,              
          166 F.2d 659, 666 (7th Cir. 1948).  Furthermore, it has long been           
          settled that a party's failure to introduce evidence within his             
          or her possession, and which, if true, would be favorable to him            
          or her, gives rise to the presumption that if produced such                 
          evidence would be unfavorable.  Wichita Terminal Elevator Co. v.            




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