Tony D. Ishizaki - Page 15




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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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