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from whatever source derived", unless otherwise provided.
Further, section 61(a)(4) provides that "interest" must be
included in income.
Petitioner admitted at trial that, during both 1991 and
1992, she held an interest-bearing checking account at United
Postal Savings Association that did produce interest in both of
those years. However, petitioner testified that, although she
had made fruitless attempts to obtain verification of the amounts
of interest, she had no evidence to show the amount of such
interest generated by this account in either 1991 or 1992.
Petitioner also admitted at trial that, during 1992, she was
the owner and beneficiary of a life insurance policy on the life
of her mother, Geneva, which policy was held by Lafayette Life
Insurance Co. and had a face value of $2,000. Petitioner
testified that she never received any interest payments from the
life insurance policy during 1992, and that the amount at issue
herein was not interest but was, rather, a dividend that was not
paid to her but was added to the value of the policy. Petitioner
produced no documentary evidence or testimony of other witnesses
to support this allegation. It is well established that this
Court is not required to accept self-serving testimony in the
absence of corroborating evidence. Niedringhaus v. Commissioner,
99 T.C. 202, 212 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77
(1986).
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