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or to list the partnership interest as one of its assets.10
Other than petitioner’s self-serving testimony, there is
absolutely no evidence of the alleged transfer in the record.
Petitioners did not introduce any contract, assignment, deed, or
contemporaneous written documentation to prove that the alleged
transfer occurred. We are not required to accept a taxpayer’s
self-serving, unverified, and undocumented testimony, and we
decline to do so here. See Tokarski v. Commissioner, 87 T.C. 74,
77 (1986).
Petitioners have failed to prove that petitioner transferred
either his partnership interest or petitioners’ alleged ownership
interest in the ranch property to his P.C. prior to the sale of
the ranch in October 1988. We hold, therefore, that the ranch
was partnership property at the time of its sale in October 1988,
that the gain from the sale of the ranch was properly included in
calculating the partnership’s income for 1988, and that
petitioner was required to report his distributive share of
partnership income for 1988 in accordance with the Schedule K-1
issued to him. In view of our conclusions, it is not necessary
10On brief, petitioners, for the first time, claim that the
P.C. reported gain from the sale of the ranch on its Federal
income tax return for FYE Oct. 31, 1989. Petitioners failed to
introduce this return into evidence at trial or to produce any
evidence that would corroborate this assertion. We conclude on
this record, therefore, that petitioners have failed to prove
that the P.C. reported any gain from the sale of the ranch.
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