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Petitioners argue alternatively that respondent’s net worth
analysis was unreliable. They assert that respondent failed to
determine accurately their net worth on December 31, 1986,
because, they claim, respondent incorrectly determined that they
had no cash on hand on that date. They also assert that
respondent’s net worth analysis failed to reflect properly
certain incidental items.
We disagree with petitioners’ claim that respondent’s net
worth analysis is unreliable. We have set forth that analysis in
our findings of fact. On the basis of our review of it in light
of the record, we are unpersuaded that respondent’s calculation
as to petitioners’ cash on hand on December 31, 1986, is
inaccurate. The record contains no reliable evidence from which
we can conclude that petitioners, in their personal capacity, had
any cash on that date.5 Petitioners’ position as to their cash
on hand rests almost entirely on their trial testimony. We find
that testimony unpersuasive in that it is uncorroborated,
inconsistent, and self-serving. See Roberts v. Commissioner,
T.C. Memo. 1987-182. Nor can we conclude that respondent did not
properly take into account various other incidental items for
5 Petitioners focus on a $63,000 loan that petitioners
received on Aug. 22, 1986, and assert that $21,000 of those
proceeds was on hand on Dec. 31, 1986. The record does not
support this assertion.
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