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certain documentary evidence. As for petitioners’ reliance on
certain testimony, we are not required to, and we shall not,
accept the self-serving testimony of Mr. Signom and Ms. Signom,
which was not corroborated by reliable evidence, that the cancel-
lation of MHR Properties’ St. Clair property interests was a
contribution or gift within the meaning of section 170(c). See
Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),
affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,
689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Nor shall we
rely on the testimony of Mr. Deas, John Hart (Mr. Hart), and Fran
Ary (Ms. Ary) to the extent such testimony suggests that peti-
tioners, as the general partners of MHR Properties, made a
contribution or gift to the University of MHR Properties’ St.
Clair property interests within the meaning of section 170(c).7
The Court found the testimony of Mr. Deas to be evasive in
responding to certain questions asked on cross-examination by
respondent’s counsel, the complete and truthful answers to which
could have adversely affected petitioners’ position under section
170.8 The Court also found Mr. Hart, the Director of Legal
7We set forth infra note 10 our views regarding Mr. Nizny,
another witness at the trial in this case.
8Despite his evasiveness in responding to certain questions,
Mr. Deas was constrained, after having been admonished by the
Court, to answer certain other questions, the answers to which
supported respondent’s position, and not petitioners’ position,
(continued...)
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