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issue.” Section 6015(b)(1)(C) expressly requires the spouse
electing relief to establish that he or she did not know or have
reason to know of the understatement, and section 6015(c)(2)
explicitly places the burden of proof on the electing spouse to
establish the portion of any deficiency allocable to him or her.
However, because such provisions do not appear to specifically
account for all requisite elements set forth in section 6015, we
in exercise of caution do not rely solely thereon.
We also point out at this juncture that in deciding whether
petitioner has carried his burden of proof, witness credibility
is an important consideration. Moreover, we are under no
obligation to accept uncorroborated and self-serving testimony.
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). In this
connection, we note that, having evaluated demeanor and content,
we found the credibility of both petitioner and Mrs. Ishizaki to
be questionable at best. Their testimony tended to be
nonspecific, inconsistent, and patently self-serving, such that
the trial at times had a decided “he said, she said” flavor.
Accordingly, our analysis below is based primarily on, and
limited by, what could be reliably drawn from the totality of the
evidence and testimony, rather than by accepting in their
entirety the statements of either spouse at face value.
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