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accounts reflected on the corporate books when York acquired Mid-
Nebraska’s business must have been made in error.
From their briefs, it appears that petitioners are under the
mistaken belief that respondent has the burden of proof in the
instant case. Generally, however, the Commissioner’s
determinations are presumed correct, and taxpayers have the
burden of proving that the Commissioner's determinations are
erroneous.3 See Rule 142(a); Welch v. Helvering, 290 U.S. 111,
115 (1933); Page v. Commissioner, 823 F.2d 1263, 1271 (8th Cir.
1987), affg. in part and dismissing in part T.C. Memo. 1986-275.
Other than their descriptive titles, the record contains no
evidence explaining the nature of the loans to shareholder
accounts. Furthermore, evidence relating to the accuracy of the
loans to shareholder accounts consisted solely of petitioner’s
testimony. We are not required to accept the self-serving
testimony of interested parties, however, particularly in the
absence of persuasive corroborating evidence. See Day v.
Commissioner, 975 F.2d 534, 538 (8th Cir. 1992), affg. in part,
revg. in part and remanding T.C. Memo. 1991-140; Niedringhaus v.
Commissioner, 99 T.C. 202, 212 (1992); Tokarski v. Commissioner,
87 T.C. 74, 77 (1986).
3The burden of proof provisions of sec. 7491 do not apply
here because the examination in this case began before July 22,
1998. See Internal Revenue Service Restructuring & Reform Act of
1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 685, 724.
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