Marian Wilson - Page 12

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          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              
          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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