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Section 61(a) provides that gross income includes all income
from whatever source derived, unless otherwise specifically
excluded. Section 102(a) excludes the value of property acquired
by gift from gross income. For income tax purposes, a gift must
proceed from a detached and disinterested generosity, motivated
by affection, respect, admiration, charity, or the like. See
Duberstein v. Commissioner, 363 U.S. 278, 285 (1960).
Petitioners rely on their own testimony and that of Mr.
Yang’s brother, Fang Long Yang. Mr. Yang testified that Fang
Long Yang opened the Bank of Taiwan account and controlled it for
Mr. Yang by making deposits and wire transferring money to the
Seafirst Bank account. Fang Long Yang testified that he did not
personally set up the Bank of Taiwan account and that he did not
know the details surrounding the wire transfers to Mr. Yang. Mr.
Yang and Fang Long Yang claim that their father made equal gifts
to his four sons during 1995 and 1996. The alleged gifts to Mr.
Yang in 1995 and 1996 were substantial ($112,077 and $224,340),
yet Fang Long Yang could not remember, or even estimate, the
amounts he received or the amounts petitioners received. We are
not required to accept petitioners’ or Fang Long Yang’s self-
serving testimony, where it is improbable, unreasonable, or
questionable. See Tokarski v. Commissioner, supra at 77; Clower
v. Commissioner, T.C. Memo. 1990-74. In light of the evidence,
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