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records, or tax returns with respect to their interest in
CME/CMA. Additionally, petitioners did not provide promissory
notes evidencing the alleged loans to CMA/CME or books and
records reflecting petitioners' lending activities. At trial,
petitioner testified that he had some books and records in
Florence, Montana. Additionally, at trial, petitioners' counsel
stated that, after petitioner sold his interest in CME during
1990, the new owner threw away most of the records.
We first examine whether petitioner's advances to CME/CMA
were bona fide debt. The parties stipulated that, for
petitioner's loans to CME/CMA, notes were prepared establishing
interest rates and maturity dates. As to the first bad debt
deduction for the worthlessness of advances allegedly made by
petitioners to CME/CMA in the amount of $633,897, however,
petitioners failed to provide the notes or any other documentary
evidence and sought to substantiate the loans only through
petitioner's testimony. We are not required to accept
petitioner's self-serving and uncorroborated testimony,
particularly where other and better evidence to prove the point
in question should be available. Wood v. Commissioner, 338 F.2d
602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964). Under the
circumstances of the instant case, we do not credit petitioner's
testimony where it is not corroborated by documentary or other
reliable evidence. Consequently, we conclude that petitioners
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