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merely transporting Abel's money to Mercedes and that no portion
thereof belonged to petitioner. Thus, our primary task herein is
to distill truth from falsehood. See Diaz v. Commissioner, 58 T.C.
560, 564 (1972). In doing so, we are aware that we must be careful
“to avoid making the courtroom a haven for the skillful liar”. Id.
Accordingly, we look for objective facts to corroborate
petitioner's account.
There are no such facts in the record supporting petitioner's
testimony. We do not find petitioner's story to be credible. We
believe that petitioner’s story is but an attempt by petitioner to
disguise his duplicity in a questionable transaction from which he
derived his ownership interest in the currency, and that he signed
the waiver disclaiming such interest in order to avoid inquiry and
possible prosecution by local authorities. Other than himself,
petitioner failed to present any witness or other evidence
corroborating his testimony. Suffice it to say, we are satisfied
that the $99,880 was his; thus, he is required to include the
$99,880 in his gross income. Accordingly, we sustain respondent's
determination that petitioner received $99,880 in unreported income
in 1993.
Issue 2: Section 6662(a) Accuracy-Related Penalty
Section 6662(a) imposes a penalty equal to 20 percent of the
amount of the underpayment attributable to negligence or disregard
of rules or regulations, or to a substantial understatement of
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