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elimination of any personal injury claims in the Biomass lawsuit
(or otherwise) as being in consideration for the benefits to be
received by petitioner (or Weisel). The option agreement
provides for agreement to be reached as to strategy and approach
to the Biomass lawsuit, but that provision is insufficient to
convince us that any of the 7.5-percent payment to Weisel was in
consideration for petitioner's giving up any claims. Weisel gave
up a greater portion of his partnership interest than did
petitioner and may have received the 7.5-percent payment in
consideration therefor. Even if we grant that, because of the
Weisel-petitioner sharing agreement, petitioner had a one-half
interest in the 7.5-percent payment, petitioner has failed to
convince us that the 7.5-percent payment was received in
consideration for anything other than the partnership interests
and other items of consideration set forth in the option
agreement. We take the pertinent agreements at face value and
accord little weight to petitioner's uncorroborated and self-
serving testimony. See Tokarski v. Commissioner, 87 T.C. 74, 77
(1986). In addition, we draw a negative inference from
petitioner's failure to present the testimony of any other party
to the transactions. Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th
Cir. 1947). In sum, petitioner has failed to convince us that
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