Ilya G. and Sophia K. Margolis - Page 8




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               To substantiate their claim regarding the $10,000 gift from            
          Mr. Margolis' mother, petitioners rely solely on their own                  
          uncorroborated testimony.  Petitioners did not produce any                  
          canceled checks or any other admissible evidence to prove their             
          claim.  We are not required to, and do not, accept petitioners'             
          self-serving testimony.  See Tokarski v. Commissioner, supra;               
          Hawkins v. Commissioner, T.C. Memo. 1993-517, affd. without                 
          published opinion 66 F.3d 325 (6th Cir. 1995).                              
               Similarly, petitioners rely principally on their own self-             
          serving testimony to establish that they deposited over 95                  
          percent of Mrs. Margolis' self-employment income to their                   
          account.  Again, we do not find petitioners' self-serving                   
          testimony sufficient or particularly reliable in that regard.               
          See Tokarski v. Commissioner, supra; Hawkins v. Commissioner,               
          supra.                                                                      
               The record in this case contains many facts contrary to                
          petitioners' testimony.  We find it unnecessary to dissect                  
          painstakingly and analyze petitioners' testimony regarding the              
          source of the unexplained deposits.  See Hawkins v. Commissioner,           
          supra.  However, as an example we refer to an instance where we             
          find petitioners' testimony to be inconsistent and improbable.              
               Petitioners testified as follows:  Mrs. Margolis would cash            
          each check--other than the first three--she received from Leo Art           
          at Hanover Bank located in the Empire State Building on the day             
          she received the check, usually on a Friday.  Mrs. Margolis would           



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