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A. Was Petitioner a “Net Lender” to Bonnevista and Castle
Towers?
Petitioners do not dispute that sometime before 1992,
Bonnevista and Castle Towers made loans to petitioner. Rather,
petitioners argue that “there were loans going both ways between
Mr. Toberman on the one hand and Bonnevista and Castle Towers on
the other hand” and that “if the loans were netted out,
Mr. Toberman would have been a net lender.” Therefore,
petitioners argue, there was no debt to forgive.
Except for petitioner’s vague and uncorroborated testimony,
there is no proof that he was a “net lender” to Bonnevista and
Castle Towers. Petitioners have failed to provide any
documentary evidence of any indebtedness from Bonnevista or
Castle Towers to petitioner. We are not obligated to accept
petitioner’s self-serving and uncorroborated testimony in this
regard, 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; Tokarski v. Commissioner, 87 T.C. 74 (1986), and we do
not.
B. Did Petitioner Repay the Loans?
Petitioners do not argue that petitioner ever repaid the
loans in question directly. Rather, they argue that petitioner
personally guaranteed third-party loans to Bonnevista and Castle
Towers, and that these guaranties ultimately resulted in
judgments against him. Petitioners failed to corroborate the
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