- 12 -
indicates that petitioner did not include distributions
apparently received from Special Occasions in calculating her
basis adjustments for the 1992 and 1993 tax years.
It is well established that we are not required to accept
self-serving testimony in the absence of corroborating evidence.
See Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992).
Petitioner has failed to establish her basis in Special Occasions
for the years in issue. We find that respondent has provided a
more credible basis computation for Special Occasions, and,
therefore, we adopt respondent's calculations. In reviewing
respondent's calculations we have found them to be very generous.
Accordingly, we find that petitioner has a basis in Special
Occasions in the amounts of $1,522 and $51012 for the 1992 and
1993 tax years, respectively. Respondent is sustained on this
issue.
2. Petitioner's Basis in Special O
A shareholder's basis in an S corporation generally includes
her capital contributions and her share of corporation income and
liabilities, less certain distributions and her share of
corporation losses. See sec. 1367(a). A shareholder's aggregate
amount of losses and deductions shall not exceed the sum of (1)
the adjusted basis of the shareholder's stock in the corporation;
12 This amount does not include any carryover basis petitioner
may have from the 1992 tax year.
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