Stan Pyron and Ruth S. Pyron - Page 8

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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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