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fraudulently or criminally. Of course, we are not required
to accept the self-serving testimony of an interested
witness. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986);
cf. Jones v. Commissioner, T.C. Memo. 1997-368. In this
case, we do not credit Mr. Stein's testimony on this point.
The principal argument of the tax matters partner is
that execution of the contribution agreement and
ratification by themselves constituted an assignment by
Mr. Stein and his wife of "all of their right, title and
interest in and to 2,000 shares of Saztec to Petitioner."
The tax matters partner further describes the contribution
agreement as "an immediate assignment of all of
Petitioner's right, title and interest in those shares"
to the trustee of the subject defined benefit plan.
The tax matters partner notes that the 2,000 shares
of Saztec stock were held in "street name" in the Steins'
account and argues that execution of the contribution
agreement was the only act required to transfer ownership
of the stock from Mr. and Mrs. Stein to the partnership and
from the partnership to the trust. He further argues that,
after the contribution agreement was executed, the Saztec
stock was placed irrevocably beyond Mr. Stein's personal
control, and any action by Mr. Stein with respect to the
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