- 9 - 2. Petitioners’ Contentions Petitioners contend that B&W did not receive barter income in fiscal year 1995 because Kelso and B&W paid each other in full after B&W’s fiscal year 1995. Badell testified that he did not tell Mr. Kelso or Blume that he would work off the cost of the roofing services. Badell testified that B&W did not try to collect the debt Kelso owed it because B&W expected that Kelso would pay B&W eventually. Badell also testified that he did not know whether the work Kelso did on his roof was a large or small project and that he did not remember seeing roofing equipment or materials at his home because he was not home during the day when the roofers were there. We disagree. We decide whether a witness is credible based on objective facts, the reasonableness of the testimony, the consistency of statements made by the witness, and the demeanor of the witness. See Quock Ting v. United States, 140 U.S. 417, 420-421 (1891); Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Pinder v. United States, 330 F.2d 119, 124-125 (5th Cir. 1964); Concord Consumers Hous. Coop. v. Commissioner, 89 T.C. 105, 124 n.21 (1987). We may discount testimony which we find to be unworthy of belief, see Tokarski v. Commissioner, 87 T.C. 74, 77 (1986), but we may not arbitrarily disregard testimony that is competent, relevant, and uncontradicted, see Conti v. Commissioner, 39 F.3d 658, 664Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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