Paul Mifsud and Maria G. Mifsud - Page 23




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          that petitioners have about that reconstruction is that respon-             
          dent failed to reduce their bank deposits for each of the years             
          at issue by the total amount of such deposits for each such year            
          that petitioners claim was attributable to their cash hoard.                
               To support their position that the source of the unreported            
          income alleged by respondent under respondent's alternative                 
          position in the answer was their cash hoard, petitioners rely               
          principally on the testimony of Mr. Mifsud and to a lesser extent           
          on the testimony of Ms. Mifsud, Ms. Mamo, and Mr. Mamo.  We are             
          not required to, and we do not, accept the self-serving testimony           
          of petitioners.  Nor are we required to, and we do not, accept              
          any testimony of petitioners' daughter Ms. Mamo or of Mr. Mamo,             
          the father of two of petitioners' grandchildren and their former            
          son-in-law, which serves petitioners' interest in this case.  See           
          Boyett v. Commissioner, 204 F.2d 205, 208 (5th Cir. 1953);                  
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Hradesky v.                
          Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d              
          821 (5th Cir. 1976).                                                        
               We found the testimony of Mr. Mifsud and of Ms. Mifsud that            
          they had a cash hoard which was the source for each of the years            
          at issue for the bank deposits at issue to be implausible,                  
          inconsistent with and/or not supported by objective evidence in             
          the record, and not credible.  By way of illustration, we found             
          Mr. Mifsud's testimony that in 1951 his father brought approxi-             





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